









就货币报告要求而言,银行包括其所有国内分行
因此,必须汇总办公室5和分支办公室事务。多种货币
在任何一次交易中,导致现金流入或现金流出总额超过10000美元的交易
如果银行知道,营业日必须视为一笔交易
由任何人或代表任何人进行。夜间、周末或假日存款
必须视为在存款后的下一个工作日收到。6.遵守
监管要求,管理层必须确保系统或实践适当
整个银行的货币交易总额,并根据以下条件报告货币交易:
BSA要求提交CTR。
受单独或汇总报告要求约束的货币交易类型
包括但不限于:存款和取款、自动柜员机(ATM)
交易、面额兑换、贷款支付、用于融资的货币交易
个人退休账户(IRA),购买存款凭证,支付资金转账
对于货币、货币工具购买,某些涉及装甲车的交易
服务、7和货币到预付费接入或从预付费接入。
在多个企业共享一个共同所有者的情况下,FinCEN指南8规定
推定为单独成立的实体是独立的人。这个芬森
指导意见指出,独立注册企业的货币交易应:
不会自动汇总为代表任何一个人,因为:
企业由同一个人所有。由银行根据
在正常业务过程中获得的信息,无论多个共享
事实上,根据所有事实和
情况。与本FinCEN指南一致,如果银行确定:
是独立的,则公共所有权不需要单独的聚合
这些业务的交易。
但是,如果银行确定这些业务(或一个或多个业务和
业主的私人账户)未单独或独立运营,或
其共同所有者(例如,企业由相同的员工组成,位于
同一地址,一家企业的银行账户反复用于支付
另一家企业或企业银行账户被反复用于支付个人费用For the purposes of currency reporting requirements, a bank includes all of its domestic branch
offices5 and, therefore, branch office transactions must be aggregated. Multiple currency
transactions resulting in either cash in or cash out totaling more than $10,000 during any one
business day must be treated as a single transaction, if the bank has knowledge that they are
conducted by or on behalf of any person. Deposits made at night or over a weekend or holiday
must be treated as if received on the next business day following the deposit.6 To comply with
regulatory requirements, management must ensure that systems or practices appropriately
aggregate currency transactions throughout the bank and report currency transactions subject to
the BSA requirement to file CTRs.
Types of currency transactions subject to reporting requirements individually or by aggregation
include, but are not limited to: deposits and withdrawals, automated teller machine (ATM)
transactions, denomination exchanges, loan payments, currency transactions used to fund
individual retirement accounts (IRAs), purchases of certificates of deposit, funds transfers paid
for in currency, monetary instrument purchases, certain transactions involving armored car
services,7 and currency to or from prepaid access.
In cases where multiple businesses share a common owner, FinCEN guidance8 states that the
presumption is that separately incorporated entities are independent persons. This FinCEN
guidance indicates that the currency transactions of separately incorporated businesses should
not automatically be aggregated as being on behalf of any one person simply because those
businesses are owned by the same person. It is up to the bank to determine, based on
information obtained in the ordinary course of business, whether multiple businesses that share a
common owner are, in fact, being operated independently depending on all the facts and
circumstances. Consistent with this FinCEN guidance, if the bank determines that the businesses
are independent, then the common ownership does not require aggregation of the separate
transactions of these businesses.
However, if the bank determines that these businesses (or one or more of the businesses and the
private accounts of the owner) are not operating separately or independently of one another or
their common owner (e.g., the businesses are staffed by the same employees and are located at
the same address, the bank accounts of one business are repeatedly used to pay the expenses of
another business, or the business bank accounts are repeatedly used to pay the personal expenses
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