Academic journal article ABA Banking Journal

Sole Proprietorships and Currency Reporting

Academic journal article ABA Banking Journal

Sole Proprietorships and Currency Reporting

Article excerpt

Q. Is it possible to exempt a sole proprietor from CTR reporting?

A. Yes, you can exempt a sole proprietor's business, but you will need to perform some due diligence before doing so.

Under 31 CFR 103.22(d)(2) (vi)-(vii) in the Bank Secrecy Act regulations, Phase II exemptions define a "non-listed business" as a "commercial enterprise to the extent of its domestic operations and only with respect to transactions conducted through its exemptible accounts and that (i) has maintained a transaction account at the exempting bank for at least 12 months, (ii) frequently engages in transactions in currency with the bank in excess of $10,000, and (iii) is incorporated or organized under the Laws of the United States or a state, or is registered as and eligible to do business within the United States or a state."

If the business meets this definition, and is not an "ineligible" business, as defined by regulation (see 31 CFR 103. …

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