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#2249906 - 03/01/21 06:04 PM Renewing CTR Exemption
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,338
Wisconsin
We have a customer that has previously been exempted, however, in 2020 they only had two transactions over the $10,000. Since they didn't meet the requirement of at least 5 transactions in a 12 month period, we need to start filing CTRs again, correct?

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BSA/AML/CIP/OFAC Forum
#2249907 - 03/01/21 06:07 PM Re: Renewing CTR Exemption CSB98
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
Correct.
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#2249936 - 03/01/21 10:02 PM Re: Renewing CTR Exemption CSB98
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If and when they hit the 5/year threshold again (for their sake, I hope it is soon), you will have to file a new DOEP with FinCEN if you want to make them exempt again.
Last edited by John Burnett; 03/02/21 04:06 PM. Reason: clarification
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#2250123 - 03/05/21 04:04 PM Re: Renewing CTR Exemption John Burnett
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Originally Posted by John Burnett
if you want to make them exempt again.
OP - Don't dismiss this option out of hand. Sometimes it's simpler and cheaper to file the occasional cookie cutter CTR and forget about the option to create a Phase 2 exemption.
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#2250286 - 03/09/21 10:03 PM Re: Renewing CTR Exemption CSB98
BOL User V2 Offline
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Joined: Dec 2020
Posts: 13
Agree.

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