https://www.ffiec.gov/bsa_aml_infobase/documents/BSA_AML_Man_2014_v2.pdfpg. 91 of the PDF lists the requirements for a Phase I exemption.
Phase I CTR Exemptions (31 CFR 1020.315(b)(1)-(5))
FinCEN’s rule identifies five categories of Phase I exempt persons:
•A bank, to the extent of its domestic operations.
•A federal, state, or local government agency or department.
•Any entity exercising governmental authority within the United States.
•Any entity (other than a bank) whose common stock or analogous equity interests arelisted on the New York Stock Exchange or the American Stock Exchange or have beendesignated as a NASDAQ National Market Security listed on the NASDAQ StockMarket (with some exceptions).
•Any subsidiary (other than a bank) of any “listed entity†that is organized under U.S. lawand at least 51 percent of whose common stock or analogous equity interest is owned bythe listed entity.
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