In regard to revoked exemptions, what documentation are we required to keep when we revoke an exemption. This will be for Phase II exemptions. What I presently keep on file is showing the number of transactions in the year that was reviewed. If the number of transaction fall below 8 the document will show it. If the account is closed I make that statement. Also Compliance indicates that I do not show that I review for possible suspicious activity. When I look at the activity I am looking for this. I guess that all I need to do is make a statement that this customer was reviewed for possible suspicious activity. Compliance indicates we should give a reason for revoking the exemption and appropriate documentation for suspicious activity be documentation.

I am trying to determine what documents that I need. They do not tell me what I need.

The bank decides which customers to exempt under Phase II based on certain criteria. Your decision should be documented. You are not required to grant Phase II exemptions, and you are not required to justify why you want to revoke an exemption. The obvious reasons would be that the account was closed or that you did not believe the account was still eligible for exemption. I would also not recommend that you continue to exempt customers that are the subject of SARs. You do not have to tell the customer that the account is no longer exempt, and I do not believe it is wise to put information in a CTR file about a customer's SARs. A simple statement that you no longer wish to exempt the customer or that the customer no longer appears to qualify should be sufficient.