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#351841 - 04/26/05 08:47 PM BSA Exempt Customer Transactions
Anonymous
Unregistered

This should be a Compliance 101 Question but I can't remember things anymore. If I have a customer exempted under Phase II, is it only deposits and withdrawals that are exempted? If they exchange small bill for large do I file a CTR?

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BSA/AML/CIP/OFAC Forum
#351842 - 04/26/05 08:48 PM Re: BSA Exempt Customer Transactions
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
A customer exempted under Phase II rules is exempted only for transactions conducted TO or THROUGH their deposit account (DDA or MMA).
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#351843 - 04/26/05 08:58 PM Re: BSA Exempt Customer Transactions
Anonymous
Unregistered

Thanks.

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