If you have doubts, as most of us would have, about the possibility of money laundering or other illegal activity, then you absolutely most not exempt. Also, at this time there is no requirement that we exempt any account. Treasury would like for us to exempt as many customers as possible in order to reduce the amount of paper that they handle. But just as CRA is not designed to encourage a banker to make an unsafe, unsound loan, the exemption rules in BSA are not there to be used for all businesses.
So, go with your "bankers' intuition" and steer clear of this one.
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Patricia Cashman,CRCM
Cashman Compliance Solutions, LLC
This is NOT legal advice