Regulatory Alerts2012-06-11
Guidance on Determining Eligibility for Exemption from Currency Transaction Reporting Requirements
The Financial Crimes Enforcement Network (FinCEN) issued this guidance to assist banks in determining customer eligibility for exemption from Currency Transaction Report (CTR) requirements following regulatory updates. The document clarifies the distinction between Phase I customers, who are broadly exempt without annual reviews, and Phase II customers, who must meet specific transaction frequency and waiting period criteria. It further addresses frequently asked questions regarding risk-based assessments, corporate restructuring, ineligible business activities, and the procedures for maintaining or revoking exempt status.
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