BSA/AML Examiner School - Case Study Oct 2023

LCB 12115

Checklist 7.4: CTR Exemptions (cont.)

Nonlisted Business and Payroll Customer Exemptions

2

1

Does the institution have a monitoring system for each exempted nonlisted business and payroll customer that is reasonably designed to detect suspicious activities? 31 CFR 1020.315(i) For each nonlisted business and payroll customer exemption, does the institution annually review and verify the information supporting the exemption, and, the monitoring system applied to each account? 31 CFR 1020.315(d)

NA NA

NA NA

Review of Exempt Accounts

1 2

Have the exempt customer's accounts been reviewed for unusual or suspicious activity?

Y Y

7 0