BSA/AML Examiner School - Case Study Oct 2023

LCB12J15

Transaction Testing Checklist 7.4: CTR Exemptions

Initial Exemption Date

Exempt Customer Name

Review Date

1 XXXX (Phase I)

04/27/2015 04/27/2015

11/03/2008 10/24/2008

XXXX (Phase I)

2

All Exemptions

1 2

For the exempted customer, has the financial institution e-filed a designated exempt person form within 30 days of the first exempted transaction? 31 CFR 1020.315(c)

y

y

Did the institution:

• Confirm that the customer met the requirements of the exemption?

Y Y

• Document the basis for its conclusions to the same extent as it would to protect itself from loan or other fraud or loss based on misidentification of a person's status? 31 CFR 1020.315(0

Y ,,

Does the customer appear in FinCEN's records as exempted by the institution?

*

Comments: *BBC is unable to determine how exempted records appear in the FinCEN Database.

6 7