Question of the Week: CTR on Joint Account

Question: 

How do I properly complete Part I on the FinCEN CTR for withdrawals from a joint account? What amounts do we show in Item 22 for each Part I? For example, John and Jane Smith have a joint account together. During one business day, John Smith withdrew $12,000 from the account. 

Answer: 

Since John Smith made a withdrawal from the joint account in excess of $10,000, then the financial institution would list Jane Smith’s information only if it has knowledge that the transaction was also being conducted on her behalf. If the financial institution does not have knowledge that the withdrawal was conducted on behalf of Jane Smith, then it would neither be required to nor prohibited from listing Jane Smith in a second Part I. 
 
Therefore, if the financial institution does not have knowledge that the withdrawal was conducted on behalf of Jane Smith, the financial institution would complete a Part I on John Smith. For Item 2 of Part I, the financial institution would check 2a “Person conducting transaction on own behalf” and complete the applicable information for John Smith. Item 22 for Part I on John Smith would be completed by entering $12,000 and providing the account number affected. 
 
However, if the financial institution does have knowledge that the withdrawal was completed on behalf of both John Smith and Jane Smith, the financial institution must complete two Part Is. In completing a Part I on John Smith, the financial institution would check 2a, “Person conducting transaction on own behalf,” and complete the applicable information for John Smith. In completing a Part I on Jane Smith, the financial institution would check 2c, “Person on whose behalf transaction was conducted,” and complete the applicable information for Jane Smith. Item 22 for each Part I would be completed similarly by entering $12,000 and providing the account number affected.