Under the Bank Secrecy Act, if a business qualifies for Phase II exemption, what type of paperwork do we need to maintain with the Designation of Exemption form? Is there something in particular examiners look for? Thank you.

Evidence of:

Date the account opened

Type of business and assessment that business does not glean more than half its revenues from the prohibited list

Number of large currency transactions conducted in past 12 months

registration or licensing to do business

What are some acceptable forms of documentation that may be used to illustrate registration or licensing to do business?

Since CIP took effect, you have been documenting the existence of all entities that open accounts. Your board adopted program should indicate what is acceptable for businesses based on what is available in your area. That documentation should meet this requirement as well.

I'm pretty sure I have seen it in writing, and I have searched today, but can anyone point to a thread discussing the ability to file Phase II exemptions on MSB customers?

Just because an entity is an MSB does not restrict them from being CTR exempt entities. You should review the 4/26/05 Interpretive Guidance of Providing Banking Services to Money Services Businesses Operating in the United States.