FINCEN CLARIFIES CTR SOLE PROPRIETOR AND DBA REPORTING REQUIREMENTS

On February 10, 2020, the Financial Crimes Enforcement Network (FinCEN) issued ruling (FIN-2020-R001) on currency transaction reporting (CTR) requirements, FinCEN Form 112, involving sole proprietorships and legal entities operating under Doing Business As (DBA) names. The changes will be effective April 6, 2020, September 1 for E-Filing batch filers. This ruling replaces FIN-2006-R003 and FIN-2008-R001.

For sole proprietorships the ruling states:

  • Complete a single Part I “Person Involved in Transaction” section with the individual owner’s name in Items 4 through 6, gender in Item 7, and date of birth in Item 17.
  • If the individual owner is doing business in his or her own name, then the rest of Part I should be completed reflecting the individual owner’s information.
  • If the individual owner is operating under a DBA name, then such name should appear in Item 8 “Alternate name,” and the rest of Part I (other than Items 4-6, 7, and 17 identifying the individual owner) be completed with reference to the DBA name.
  • If the individual owner operates under multiple DBAs, enter only one “Alternate name” in Item 8, then complete a separate Part I section should be completed for each different DBA involved in the transactions.
  • The amount and account number(s) entered in Item 21 (Cash In) or Item 22 (Cash Out) will be associated with the specific location corresponding to the reported transaction.

For legal entities the ruling states:

  • When a CTR is prepared on a legal entity a Part I section should be prepared containing the home office/headquarters data (address, telephone number, identification number, etc.) of the entity.
  • When multiple entity locations are involved a separate Part I section should be prepared for each location involved.
  • Each additional Part I section should include the entity’s legal name in Item 4 and alternate name, if any, in Item 8.
  • When there are multiple DBA names involved in the transaction, Item 8 “Alternate name” should be left blank in the entity home office Part I section.
  • Each additional Part I section will include the location’s address along with all other location or entity data applicable to that location.
  • When the entity home office address is the same as the transaction location, only a home office Part I section should be prepared.
  • The amount and account number(s) entered in Item 21 (Cash In) or Item 22 (Cash Out) will be that associated with the specific location. The initial Part I section on the entity home office/headquarters will show the total amount and all account numbers involved in Item 21 or 22.

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