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#645619 - 12/01/06 04:58 PM Exemption - Phase I
AML Officer with a question Offline
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Joined: Apr 2006
Posts: 6
Could someone please tell me if Colleges and Universities qualify for a Phase I exemption? Please include a citation.

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#646096 - 12/01/06 11:50 PM Re: Exemption - Phase I AML Officer with a question
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
A state college or university could qualify as an arm of state government, in my opinion. Other colleges and universities would not meet any of the Phase I criteria, as far as I can tell.

I'll add to the list any of the military service academies.
Last edited by John Burnett; 12/01/06 11:52 PM.
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#646256 - 12/04/06 11:02 AM Re: Exemption - Phase I AML Officer with a question
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Exemptions are discussed in 31 CFR 103.22 and the characteristics of governmental entities or departments are outlined there. As John notes, some entities, including hospitals and colleges, are supported by he government's power to tax and some are not. The answer is "fact based."
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