What to do when the depositor is a sole proprietorship

In a ruling issued in January 2008, FinCEN clarified how a currency transaction report should be completed when the transaction is conducted by or on behalf of a sole proprietorship. [FIN-2008-001, January 25, 2008]

Reporting a transaction conducted by or on behalf of a sole proprietorship could be confusing because many people think of a sole proprietorship as an entity separate from its owner. The law does not; there is no legal distinction between a sole proprietorship and the person conducting business through it. But how you view sole proprietorships could affect the way you complete the CTR .

The FinCEN ruling allows for two methods. The preferred method is that you complete the CTR only with information about the owner of the sole proprietorship. You fill in the individual’s name, the individual’s social security number, home address, date of birth and occupation. (You would, however, include the “doing business as” name.)

The alternative is to complete two fields, one for the individual owner and one for the sole proprietorship. You would use the “Multiple Persons” field.