Hello! This is my first post here, and I apologize if this question has been asked / answered in the past.
2021 will be the first time that I am completing the annual review for customers that are exempt from CTR's, and I am wondering what other FI's procedures look like. Currently for Phase 2 customers our procedure is a bit repetitive, and I am looking to change this.
In the past, and for Phase 2 exempt customers only, the BSA officer would reach out to the branch and have them complete an exempt customer monitoring checklist. This checklist has the banker acknowledge that the exempt customer's activity has remained the same since the last review, and they sign off on it. The BSA officer would also send a similar form to the customer. This form would have the customer acknowledge that their activity has remained the same and that the nature of their business has not changed (among many other things). On top of this, the BSA office would do an individual review of the customer's activity by obtaining proof that 5 CTR's were generated but excluded, look at risk factors and cash activity from the previous year - current.
I am looking to simplify this process by keeping everything in the BSA department, and would like to not involve the customer or the branch. Can anyone share what their annual review process for Phase 2 customers looks like? Is it similar? Do you also include the branch and the Phase 2 exempt customer in your review?
Any information, tips, guidance is extremely helpful and greatly appreciated!!
Thank you so much!