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#1558970 - 06/01/11 03:22 PM Exemption Documentation
cheech Offline
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Joined: Jun 2010
Posts: 207
Chatsworh PA
We are currenly writing down the dates that cash deposits exceeded $10,000 and a CTR was filed on each exemptable customer until we have five dates, then we stop keeping track. An auditor told us we needed to beef up our documentation but it was not an official write up. Any suggestions / comments?

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#1558990 - 06/01/11 03:34 PM Re: Exemption Documentation cheech
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
When you complete your research to determine whether an exemption is allowable, I suggest you record information on all of the qualifying deposits (not just the first five), the date the account opened, and something to indicate how you determined that the business doesn't get more than half its gross revenue from prohibited business types.
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#1559001 - 06/01/11 03:40 PM Re: Exemption Documentation cheech
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
So, when you are looking for your car keys and you find them your auditor would advise you to keep looking?

Once you can document the frequent large cash transactions requirement for the exemption process you are not required to make a catalogue of all large cash transactions. You can verify that with a call to FinCEN. If you want to review all of the customer's large cash transactions it is for a different purpose.

As an aside, any handmade list of transactions you use in support of exemption should be supported by copies of the underlying documents; i.e. an undocumented list will not be acceptable.
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#1559125 - 06/01/11 05:29 PM Re: Exemption Documentation Elwood P. Dowd
cheech Offline
100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
Thx for the help.

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