Thread Options
#2254435 - 05/26/21 02:38 PM Pandemic's Effect on Phase 2 CTR Exemption Review
AUTigers65 Offline
Member
Joined: May 2006
Posts: 56
This year's Phase 2 CTR exemption review was depressing due to the large number of exempted customers that did not meet the requirement for exceeding $10k in cash on at least five days in the past year. Did FinCEN and/or Regulators address this and perhaps I overlooked it?

Return to Top
BSA/AML/CIP/OFAC Forum
#2254437 - 05/26/21 02:48 PM Re: Pandemic's Effect on Phase 2 CTR Exemption Review AUTigers65
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,237
Illinois
There are no changes to the eligibility requirements for exemptions. You will have to revoke exemptions and then file new DOEPs after your customers again have five reportable transactions within 12 months.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2254440 - 05/26/21 03:06 PM Re: Pandemic's Effect on Phase 2 CTR Exemption Review AUTigers65
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,588
Cape Cod
Remember that you don't have to file a DOEP to revoke the exemptions -- you just have to resume filing CTRs on these customers. Once you have filed four CTRs and are about to file the fifth on one of the customers in a 12-month period, you can file a new DOEP to exempt them again.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z