We have a low-end jewelry store in a small town that buys gold, coins and old jewelry. They take out large amounts of cash for these purchases and to take to jewelry auctions. They have indicated on our CTR exemption questionnaire that they are not involved in pawn brokerage. But I'm not sure about whether we should allow an exemption based on this type of activity. What do you think?

Thank you!

I always say, "When you get confused, go back to the basics."

Here is the reg:
(viii) Ineligible businesses. A business engaged primarily in one or more of the following activities may not be treated as a non-listed business for purposes of this paragraph (d):
-serving as financial institutions or agents of financial institutions of any type;
-purchase or sale to customers of motor vehicles of any kind, vessels, aircraft, farm equipment or mobile homes;
-the practice of law, accountancy, or medicine;
-auctioning of goods;
-chartering or operation of ships, buses, or aircraft;
-gaming of any kind (other than licensed parimutuel betting at race tracks);
-investment advisory services or investment banking services;
-real estate brokerage;
-pawn brokerage;
-title insurance and real estate closing;
-trade union activities;
-and any other activities that may be specified by FinCEN.
A business that engages in multiple business activities may be treated as a non-listed business so long as no more than 50% of its gross revenues is derived from one or more of the ineligible business activities listed in this paragraph (d)(6)(viii).

I would say that none of what you have described fits any of the above. I would exempt them if you so choose AND if you have determined that the activity is not suspicious.