I'm conducting an internal audit of BSA, and it was identified that the Bank did not complete the annual review of exempt customers timely (well overdue). Had the review been conducted timely, it would have been identified that one customer no longer met the Phase II exemption requirements. This customer also has had CTR reportable transactions after the 1st year of exemption. Am I correct in assuming that these CTRs should be filed - even if they are late?

contact FINCEN for sure but thinking the answer will be a YES