Can a bank exempt an MSB from having to file CTRs? This company cashes checks as part of a convenient store that also has a restaurant in it. The majority of their money comes from store and restaurant sales no the check cashing. Thanks

If you are asking about letting the MSB get around having to file CTRs if they cash checks in excess of their CTR trigger amount, the answer is an emphatic "no."

Well, that they do is come and get money from their account to take back as working money, then they come in and make a deposit of yesterday's items plus cash from the store's and restaurants sales. From what I have seen, there has never been anything over $10,000 that they have cashed.....can they be exempt? I am speaking about us filing one on them when they ask us for cash in excess of $10,000......

The BSA/AML exam manual states "a business that engages in multiple business activities may qualify for an exemption as a non-listed business as long as no more than 50% of its gross revenues per year are derived from one or more of the ineligible business activities listed in the rule."

With that being said, I urge you to read the updated guidance (FIN-2009-G001) which contains, reviewing certain supporting documents for proof of income percentage.

That's right. Although you'd still want to subject the MSB transactions to the appropriate level of extra due diligence you impose on such high-risk accounts, unless the MSB fails the 50% test and is not ineligible for other reasons, you could consider exempting the MSB.