Currency Transaction Report Aggregation for Businesses with Common Ownership

The Financial Crimes Enforcement Network (FinCEN) is issuing guidance to clarify, for currency transaction reporting (CTR) purposes, the aggregation of multiple transactions conducted by businesses with common ownership.

It is ultimately up to a financial institution 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. The results of this determination affect whether the businesses’ currency transactions should be aggregated for purposes of complying with CTR obligations.

There are no universal rules applicable to any situation. Once a financial institution determines that the businesses are independent, then it should not aggregate the separate transactions of these businesses. Alternatively, once a financial institution determines that the businesses are not independent of each other or their common owner, then the transactions of these businesses should be aggregated going forward.


Questions? Contact the Compliance Hotline: 1.800.546.4465,

Posted in Compliance News, Events.