Designation of Exempt Person
FinCEN has published a proposal to make subtle changes to the form for Designation of Exempt Persons. The proposal is intended to simplify the form and its use. FinCEN has redesigned several of the data elements based on calls to its help line and comments from bank regulators. The instructions would be expanded and clarified to give more help to the user. Hopefully, the clarifications will also result in better use of the form. Finally, the certification for suspicious activity monitoring would be made on behalf of the filer and any bank subsidiaries. Other than that, there isn't much change. Comments on the proposal are due to FinCEN by February 25, 2005.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 1, 1/05
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