Are majority or wholly owned subs of US publicly traded entities excluded from the definition of a customer? I looked at how exclusions from the definition of a "customer" are defined and it points to the CTR Exemptions. Based on my review it looks like subs of publicly traded entities are not excluded from the definition of a customer?

Has any one run into this before?

Actually, you are correct:

1020.100(c)(2) Customer does not include:

(ii) A person described in §1020.315(b)(2) through (b)(4);

Subsidiaries are actually found in §1020.315(b)(5)

Thanks Randy.