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When filing a CTR on a business, should we report the address of the business when there is no person stationed at that address and the headquarters of the business has a separate address? For example, where a Laundromat has no attendant and receives mail at the corporation’s address on file with the Secretary of State and the IRS? – IBA Compliance Connection

IBA Compliance Connection

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When filing a CTR on a business, should we report the address of the business when there is no person stationed at that address and the headquarters of the business has a separate address? For example, where a Laundromat has no attendant and receives mail at the corporation’s address on file with the Secretary of State and the IRS?

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We believe that the CTR should use the address of the business headquarters, not the address of the physical location where the reportable transaction took place. FinCEN addresses analogous situations in its guidance, in which a business has multiple locations and where the reportable transaction takes place at a location separate from the business headquarters. In each example provided by the guidance, FinCEN provides a sample CTR that reports the location of the controlling interest of the operating entity.

For resources related to our guidance, please see:

  • FinCEN, Frequently Asked Questions Regarding the FinCEN Currency Transaction Report (CTR), Question 26, Examples 1–3