BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 7.4: CTR Exemptions (cont.)

Phase H Exemptions ("nonlisted business" exemptions

1

2

Is the business of a type that is eligible for an exemption? 31 CFR 1020.315(f)

NA NA

Note: This should include documentation to support that the "nonlisted businesses" it has designated as exempt from CTR reporting do not receive more than 50 percent ofgross revenue from ineligible business activities. Has each nonlisted business displayed the following: • Maintained a transaction account at the institution for at least 2 months or sooner if supported by internal risk assessment? 31 CFR 1020.315(b) • Frequently (5 times per year or more) engaged in transactions in currency with the institution in excess of $10,000? 31 CFR 1020.315(b) • Incorporated or organized under the laws of the U.S. or a state, or registered as and eligible to do business within the U.S. or a state? 31 CFR 1020.315(b)

NA NA

NA NA

NA NA

Comments: The Bank does not have any Phase II exemptions.

6 9