BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 7.4: CTR Exemptions (cont.)

Phase I Exemptions (automatically exempt customers

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Does the customer qualify for the exemption? 31 CFR 1020.315(b)

Y Y

Does the institution conduct ongoing and reasonable due diligence with respect to this customer, including annual reviews for certain customers to determine whether a customer remains eligible for designation as an exempt person under the regulatory requirements?

Y Y

Comments: The Bank provided a list of two Phase I exemptions. Both are listed on an exchange.

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