Regulatory Alerts2002-11-01
Added
Guidance On Interpreting “Frequently” Found In The Criteria For Exempting A “Non-Listed Business” Under 31 C.F.R. §103.22(d)(2)(vi)(B)
The document interprets the term “frequently” for exempting non-listed businesses from Currency Transaction Report requirements under 31 C.F.R. §103.22(d)(2)(vi)(B), defining it as a recurring or routine need to conduct large currency transactions in the ordinary course of business. It establishes a general threshold of at least 8 large currency transactions annually, or approximately every six weeks, to demonstrate this frequency, with specific provisions for seasonal businesses to meet this count during their operating periods. Depository institutions are advised to make good faith determinations on a customer-by-customer basis and are protected from civil money penalties for failing to file CTRs for eligible exempted customers, while remaining obligated to monitor for and report suspicious activity.