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September 9, 2009 -The Financial Crimes Enforcement Network (FinCEN) published FIN-2009-G003, Guidance on Determining Eligibility for Exemption from Currency Transaction Reporting Requirements. The guidance addresses frequently asked questions regarding new currency transaction reporting (CTR) requirements that went into effect January 5, 2009.
New requirements included:
- Elimination of designation and annual review for customers who are other depository institutions operating in the United States, U.S. or State governments, or entities acting with governmental authority. These “Phase I” customers will now be automatically exempted.
- Threshold to designate an otherwise eligible non-listed business customer for exemption lowered to after the customer has within a year conducted five or more reportable transactions in currency (previously, eight or more reportable transactions were required).
- Waiting time for eligibility decreased to allow a hybrid approach to designate an otherwise eligible customer for a Phase II exemption: The customer may be eligible for exemption after maintaining a transaction account for two months (previously 12 months were required); or, the customer may be eligible for exemption in less than two months after a risk-based analysis is conducted.
To view the FinCEN guidance on CTR filing and frequently asked questions, click here:
http://www.fincen.gov/statutes_regs/guidance/html/fin-2009-g003.html.
For more information, please contact Brian Knight, brian@nascus.org.
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