Regulatory Alerts2019-12-04 | HTMLAdded
Clarification of Time for Designation of Exempt Persons for Purposes of 31 CFR 103.22(h)
The Financial Crimes Enforcement Network clarifies that institutions may designate customers as exempt persons under 31 CFR 103.22(h) after August 15, 1996, even if those customers were existing before May 1, 1996. This designation must be filed within 30 days after the first currency transaction between the institution and the exempt person that occurs after April 30, 1996. The clarification applies retroactively to May 1, 1996, allowing institutions to adopt the exemption system for existing customers provided the required Internal Revenue Service Form 4789 is submitted within the specified 30-day window.
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