by Randy Carey: All transactions with a Phase I customer are covered by the exemption. Only non-listed business are limited to transactions in or out of their transaction or money market savings accounts (1020.315(e)(9)). A governmental agency is not subject to an annual review (1020.315(d)).
by Ken Golliher: In full agreement, but to say the same thing differently: It is wrong to file a CTR on a government entity. Any reviewer could justifiably criticize your bank's 1) training and 2) internal controls.