Introductory BSA/AML Examiner School, Atlanta, CA

Bank of Smithville USA

Page 13

review determined the 20XX checks were purchased with five, $10,000 CSB cashier’s checks, obtained on varying dates in 2015. The customer received the remaining $2,500 in cash. BSA Officer Marks concurred that the seven instances appeared to be designed to circumvent the submission of CTRs, and management created cases during the examination. Improper designation of exempt person Section 1020.315(a) through (k) of the Treasury Department’s Bank Secrecy Act regulations allows covered financial institutions to exempt certain customers from the currency transaction reporting requirements provided those customers meet the criteria specified in Section 1020.315(b). As part of the merger with HILL Bank, management inherited a customer that had been designated as a Phase II entity exempt from CTR reporting. The customer operates an armored car service, which is considered an ineligible activity and does not qualify for exempt status. The exempt status should be revoked and FinCEN should be contacted to obtain a CTR back filing determination. During the onsite portion of the examination, BSA Officer Marks contacted FinCEN. She was notified to back file CTRs for the period of August 4, 20XX to August 3, 20XX, and those CTRs were submitted on September 6, 20XX.