Regulatory Alerts2008-12-04
Added
Amendment to the Bank Secrecy Act Regulations – Exemptions from the Requirement to Report Transactions in Currency
FinCEN amends 31 CFR 103.22 to remove the requirement for depository institutions to file an initial FinCEN Form 110 and conduct annual reviews for Phase I exempt customers that are depository institutions, government agencies, or entities exercising governmental authority. The rule also eliminates the biennial renewal filing requirement for Phase II exempt customers, though institutions must still report changes in control every two years. Additionally, the amendment permits depository institutions to exempt eligible non-listed business customers who frequently engage in large currency transactions within a period shorter than the previous 12-month waiting period. These changes take effect on January 5, 2009.
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