Annual CTR Exemption Review - UBO Trigger?

Hi all,

I have been given the heads up by our auditor that they are going to be looking for the CTR Exemption Annual Review to be a trigger for getting beneficial ownership on our existing customers. Has anyone else built this into their program or heard of this being a requirement they will be expected to fulfill?
It seems cumbersome to require it of these customers every year and I am sure I will get push back from the retail side of things when I ask for it annually. Is anyone using an attestation of no changes instead? How are you working that into your process?

Thanks!

We don't plan to do this and will not if an auditor suggests it.

In our annual reviews of high-risk and exempt customers this we are collecting the information. We won't be asking the customers to recertify each year going forward if we already have it on file, unless our review turns up specific information that it may have changed.

Give them a "heads up" that you are expecting helpful advice relative to compliance, not a make work suggestion.

Find a new audit firm. Idiots.

Was that auditor a six-foot rabbit, by any chance?