I am an Internal Auditor currently working on a Bank Secrecy Act Audit. I have been reviewing our CTR exemption list after collecting names of correspondent banks that our bank branches either receive currency from or provide currency to within the past year. I have noticed that some of the correspondent banks that our branches exchange currency with are not on our exemption list. Is there any advice you can give me as to when these correspondent banks should be included on the exemption list? I think that we should include any and all correspondent banks because how do we know if we will be exchanging over or under $10,000? Wouldn't it be best to include them on the exemption list as a precautionary measure? Any advice you can give me will be helpful. Thank You!

I believe a one-time Designation of Exempt Person form is required to be filed for every correspondent bank with which you engage in currency transfers.

I am wondering the same thing. I am the BSA Officer and have been for the last 8 years. My question is: when I took over the role of BSA Officer from our previous BSA Officer, there were three correspondent banks listed on our Exemption List, but we do not have any proof of mailing in an exempt person form. Do I need proof or do I just take the previous BSA Officer's word for it?

I would file another Designation of Exempt Person form for the correspondent banks, because examiners are going to want to see them. Also document that you are refiling the forms because the original forms (if there ever were any) could not be located.

As long as you haven't conducted cash transactions over $10,000 with any of them, you haven't violated the regulation by not filing. However, I agree, that it's an easy exemption to file, the risks of missing a potentially reportable transaction are higher, since those transactions usually don't flow through your normal reporting processes, so why not file them.