BSA Guidance for DBAs

KPM financial institutions update header link to blog.

28 Feb BSA Guidance for DBAs

The Department of the Treasury Financial Crimes Enforcement Network (FinCEN) requires financial institutions to file currency transaction reports (CTRs) for certain cash transactions, and many transactions are performed by persons or legal entities doing business under a different name or names. FinCEN has provided clarification on filing CTRs (Form 112) on sole proprietorships and legal entities using ‘doing business as’ or DBA names effective April 6, 2020. While the ruling is brief and can be found at https://www.fincen.gov/index.php/resources/statutes-regulations/administrative-rulings/fincen-ctr-form-112-reporting-certain, below is table highlighting FinCEN’s guidance on CTR filings using DBA names. The guidance clarifies what information needs to be provided on Part I of Form 112 when filing on single and multiple DBA names. The guidance breaks down filing guidance for sole proprietors and legal entities.

Conducts Transaction: Part I Items 4-6, 7, & 17 Rest of Part I Items 21 & 22
Person in own name Owner information Owner information Enter amounts & account #s for the specific location of the transaction
Person in DBA name Owner information DBA name information
Person in multiple DBA names Owner information on each Part I DBA name information for each DBA
Conducts Transaction: Initial Part I Additional Part I(s) Items 21 & 22
Legal entity – one location conducting transaction Home office / headquarters data Data on location of transaction (if different from home office) The initial Part I section on the entity home office / headquarters will show the total amount & all account numbers involved in Item 21 or 22; Enter amounts & account #s for the specific location of the transaction
Multiple entity locations (aggregated CTR) Home office / headquarters data

If multiple DBA names, leave Item 8 blank

Entity’s name & alternate name in Items 4 & 8 on each Part I

Location information for rest of Part I

Keep the above information as a reference when completing CTRs, and contact KPM Manager Richard Dugas with any additional questions.