Regulatory Alerts2009-04-27
Added
Guidance on Supporting Information for Determining Ineligible Revenue Portion for Currency Transaction Reporting Exemptions
Banks must maintain supporting information to substantiate a reasonable determination that a non-listed business customer derives no more than 50 percent of its annual gross revenues from activities ineligible for exemption from currency transaction reporting requirements. This guidance specifies that banks may rely on customer checklists, self-certifications, tax returns, or financial statements to verify this revenue threshold, particularly when it is not clear from ordinary due diligence that the customer qualifies. Banks are required to review and verify the information supporting each exemption designation at least once per year.
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