By: Nash Cullens
On February 10, 2020, FinCEN issued guidance to help clarify a previous ruling on how to file CTRs relative to sole proprietors and entities operating with a trade name or “doing business as” name (DBA). The new rulings go in effect for discrete filers on April 6, 2020, and September 1, 2020, for batch filers.
The new ruling (FIN-2020-R001) was intended to help clarify how CTRs should be filed for sole proprietorships doing business under a single alternate name in a single location as well as for sole proprietorships doing business under multiple alternate names and locations. The ruling also helps to clarify how to file CTRs on legal entities doing business under a single alternate name in a single location as well as legal entities doing business under multiple alternate names in multiple locations.
The following links contain the rulings and guidance on how to file CTRs for each scenario.
Use the following link to access the full article released by FinCEN:
https://www.fincen.gov/sites/default/files/administrative_ruling/2020-02-10/FinCEN_CTR_Form112_508_1.pdf
Also, for examples on how to complete a CTR for each scenario, please reference the CTR FAQs # 26:
https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr
For E-Filing instructions, please reference Page 90, Items 17 and 18 of the following links:
https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf
On February 10, 2020, FinCEN issued guidance to help clarify a previous ruling on how to file CTRs relative to sole proprietors and entities operating with a trade name or “doing business as” name (DBA). The new rulings go in effect for discrete filers on April 6, 2020, and September 1, 2020, for batch filers.
The new ruling (FIN-2020-R001) was intended to help clarify how CTRs should be filed for sole proprietorships doing business under a single alternate name in a single location as well as for sole proprietorships doing business under multiple alternate names and locations. The ruling also helps to clarify how to file CTRs on legal entities doing business under a single alternate name in a single location as well as legal entities doing business under multiple alternate names in multiple locations.
The following links contain the rulings and guidance on how to file CTRs for each scenario.
Use the following link to access the full article released by FinCEN:
https://www.fincen.gov/sites/default/files/administrative_ruling/2020-02-10/FinCEN_CTR_Form112_508_1.pdf
Also, for examples on how to complete a CTR for each scenario, please reference the CTR FAQs # 26:
https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr
For E-Filing instructions, please reference Page 90, Items 17 and 18 of the following links:
https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf
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