During our annual review of our exempts, we had been primarily focusing on the transactions, that it met criteria. We are now compiling more EDD in which to ensure exempts to do not have ineligible business activities over 50% of gross revenue. (Example beer distributor that sells lottery tickets, or grocery store that issues money orders.) But basicly showing that we have obtained enough EDD to be comfortable that the business is not engaging in any ineligible business activities and is supporting their stated business activities.
During CTR reviews, what information do you examine?
-transaction history
-financials to show business activity
-....
or do most banks predominately just examine transaction history and sufficient CDD/EDD that business has no ineligble activities?
Last edited by Othom; 12/11/14 03:52 PM.
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Giving my two cents, which you can take to the bank, or wait for other's before going.