-We have a non-customer government agency that comes into our branches to turn cash, guessing from "siezures", into cashiers checks. They hold no accounts, but they are an exempt entity. Previously we had them on the exemption list, but I have started documenting annual reviews and unsure to have non-customer, with infrequent transactions. But do we file CTR everytime they come in? Has anyone had a government agency or Phase I non customer transact in their branch to trigger CTR? Curious anyone's thoughts on how to document.

Thanks, ps. first time poster, but great site, very invaluable to new hire.

Just read older post about exemptions for "other Financial Institutions" answered my question. Once again, this site is great.

Welcome to the world of posters, Othom. We look forward to your contributions to our collective wisdom, occasional humor, and frequent commiseration with fellow workers in the trenches of banking and BSA/AML.

As you no doubt read in that older post (I'm posting here for those who haven't found the older post yet), an account relationship isn't required for you to avail yourself of the "Phase 1" exempt-person status of a government agency, bank, or listed business or 51% subsidiary of a listed business (exempt persons under 31 CFR 1020.315(b)(1)-(5)).