I thought that I read or found out somehow, that we were not required to perform an annual review on banks, government agencies, etc once they were exempted under the Phase 1 criteria......
However, when I read the BSA Currency Transaction Reporting Exemption Overview, the Annual Review is still listed as required.....
This bank has performed one annual review on 1999 initial exemptions. They have been examined since and nothing was noted......
Is that annual review required?
Thanks,
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Riding the waves of change.....2014