Is the exempt list (for a phase II) at the customer level or account level? If one account meets the qualifications during the review, does only that account get exempted or do all accounts for that customer get exempted? Thoughts?
The exemption includes all accounts that you incorporated in your review in order to conclude that the customer "frequently" has large currency transactions. If you initially and annually review them all, then the customer itself is exempt. Question 13
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.