Skip to content
BOL Conferences
Thread Options
#335382 - 03/18/05 03:56 PM Phase I exemption question
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
I did a search for this before posting but I wasn't finding the exact answer.

Question 1: We have to file a one-time Phae I exemption for our Correspondent Bank that we buy and sell money from. This is not a Federal Reserve bank. - True/False.

Question 2: We contract with a different correspondent bank to fill our ATMs with cash. Again not a Federal Reserve Bank. Do we need to file a Phase I exemption? I think not because the transaction is not received into a deposit account at the bank.

This issue came up during our BSA meeting yesterday and the more they kept pressing the issue, the more I began doubting my own opinion.

Return to Top
BSA/AML/CIP/OFAC Forum
#335383 - 03/18/05 04:00 PM Re: Phase I exemption question
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Question 1. True, unless you wish to file a CTR for every cash transaction over $10,000 with that bank.

Question 2. File the exemption. You don't have to receive cash into a deposit account to take effective possession of cash. Think about a cash loan payment over $10K. You'd report it. Think about your cash purchase from the correspondent in question 1. That isn't received into an account. Consider a currency exchange over $10,000, which also doesn't affect an account. You'd do a CTR, right?

You don't have to have an account relationship with a Phase I exempt person to designate it as exempt.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z