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Compliance Alliance Featured Q&A
Bank XYZ has a Phase II Exemption customer that is no longer eligible for the Currency Transaction Reporting (CTR) Exemption since they haven’t had five or more transactions over the CTR threshold in 2020. What do they need to do?
Bank XYZ would need to start filing CTRs as appropriate and cease treating them as exempt. There is no need to backfile CTRs. For more information, visit Guidance on Determining Eligibility for Exemption from Currency Transaction Reporting Requirements (E: Customers no longer eligible for exemption).
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