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