Anyone notice that the codified BSA regulations on Fincen's website are outdated? I was looking at the currency transaction section to look up exemption info and it still had the old info (account for at least 12 months, more than 8 transactions, biennial renewals for phase 2). Couldn't believe it still had the old info, not good!

As with most federal govt. employees, FinCen moves at their own pace.

It's crazy!!! If someone was new to BSA and looking for guidance on BSA, Fincen would most likely one of the first places they would look. We're going on 9 months now, you'd think they'd update regulations area more frequently!

Here is my question, we have a customer that we exempted last year. It's time for thier annual review (phase II) and I noticed that haven't had cash trans. over $10,000 in cash over the last 6 months, other than one day. So, I don't belive they are still eligible. Do I need to file a revocation still? If so, on the DOEP? I couldn't find my answer.

You are not required to report a revocation.

Have you considered extending the timeframe of your review to the past 12 months? Your customer may have only had one reportable transaction in the past 6 months, but if you look at the past 12 months, they may have met the threshold of five reportable transactions to remain eligible.

Sometimes you just cannot trust FinCEN. If you want an
up-to-date version of 31 CFR 103, go here

http://tinyurl.com/nsxuvr

FinCEN's link is to the officially codified version of the regulation, which is was last updated in July, 2008. The e-CFR version, linked by Retread, is current.

Unfortunately, linking to the official, codified regulation isn't much help. Can you even imagine looking at the official codified version of Regulation Z for current information?