FinCEN Sheds Light on Exemptions by Mary Beth Guard, BOL Guru
In order to exempt a non-list business from the CTR requirement, one criteria that must be met is that the business "frequently" engages in large currency transactions with your institutions. Until recently, there was no clear explanation of what "frequently" meant. FinCEN has finally issued guidance on the subject and is encouraging institutions to use the exemption regulation to the fullest extent to exempt all eligible customers.
"Frequently" means a routine or recurring need. In general, that means the customer conducts at least 8 large currency transactions throughout the year (approximately every six weeks). A seasonal business, however, may conduct the 8 large transactions in a shorter period of time.
The non-listed business' account must be opened for at least 12 months to qualify for the exemption.
The original version appeared in the December 2002 edition of the Oklahoma Bankers Association Compliance Informer.
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