In the past, we've only added to the exemption list during the month of review (March). Does anyone else follow this pattern or do you exempt at any point once a business qualifies? Note: we have less than 10 exemptions.

We generally follow the same process as you. We rarely get a new business that generates so many CTRs that we'd exempt them during the year, but it could be possible.

I exempt mine as I go, but I re-review them at the same time as my others to get them on the same annual schedule.

Thank you.

If I add 1 or 2 in May-Dec of 2017, it's still ok to review all the exemptions in March? It doesn't have to be a time frame of 12 mos to review?

It does not have to be a time frame of 12 months, assuming that they have met the "frequently" criteria (five or more reportable transactions). The more relevant criteria is that they have to have maintained a transaction account at the exempting back for at least two months (although there is an exception to this as well). So if you add them late in the year, your review in March would have given them the two months needed, assuming they've gone over the 5 transactions.

Thank you.