I want to exempt a corporation that has accounts with us in the corporate name alone and also in the corporate name with a d/b/a. Are these considered seperate persons and require 2 different exemptions or are they just one person? The same TIN is used on both accounts. I guess you can tell that I am new at BSA and at "Threads". Help!

For exemptions (Phase I and II), you are looking at the Tax ID. Assuming they are are using the Tax ID for the same type of business, then one exemption will cover all DBA's under that umbrella. Also, make sure they have had a relation with your bank for at least 12 months and have 8 or more reportable transactions per year. A general rule I try to use is 12 reportable transactions to help eliminate the need to revoke any next year due to having too few. I'm guessing you already know, but make sure they don't do more than 50% of any ineligible activities and that you have a small file for your exempt customers with your completed due diligence. Welcome to the BSA world.

Thanks GMetz! That helps a lot.

You have our condolences. This is a tricky corner of the world of regulatory risk management and the only banking regulation with a death penalty (for your institution. Individuals only face 20-yr prison terms.)

If you research this heavily-discussed topic, you will run across the contrarian view that Phase II exemptions do not represent an acceptable cost/risk/reward ratio in many cases. You are not required to have exemptions, and for many customers with cash spikes it's cheaper to file the handful of CTRs each year than to set up and maintain an exemption.

Examiners crawl all over exemptions, and you'll certainly be cited for even the smallest infraction or oversight. Over the years, exemption errors have lead to some of the biggest penalty cases.

Unless the net savings (CTR filing cost minus cost of exemption administration) are substantial, a Phase II exemption trades a sizeable risk for an insignificant reward. Know your filing costs and weigh the alternatives carefully.

Good luck in your new job!