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Annual Cash Aggregation?!

FinCEN is working on the Phase II exemption rules. This involves looking for appropriate methods to reduce regulatory burden and exempt companies that are not listed on a major stock exchange. The concern - especially of the law enforcement participants - is that they have some method of identifying changes that may indicate new or suspicious activity. One proposal on the table is to require banks to report the annual total aggregate cash transactions for Phase II exempted companies. You are encouraged to comment when the proposal comes out (hopefully no time soon) if you believe - as do most of us - that aggregating the total cash transactions of a business customer for an entire year would be complicated or downright burdensome.

Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 9, 8/97




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