Under phase 1, transactions conducted by banks, government departments or agencies, and listed public companies and their subsidiaries are exempt from ctr reporting. The ffiec bsa/aml manual breaks down the entities eligible for a ctr exemption into two groups, phase i and phase ii entities. Certain entities are exempt from ctr reporting, and fall under either the phase i or phase ii category for exempt status
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Which entity is included in the phase ii category for exempt status?
Franchisees of listed corporations (or of their subsidiaries) are not included within the definition of an “exempt person” under phase i unless such franchisees are independently exempt as listed corporations or listed corporation subsidiaries.
We have a county government agency, that falls under a phase i exemption, but up until this point we haven’t treated them as exempt All our other phase i exempt customers have been in place for years, and we have a doep on them Is this still required of phase i exempt entities Or what must be done now for a phase i exemption?
Under phase i, banks, government agencies, and listed public companies are exempt from ctr filing requirements 1020.315, a financial institution can exempt transactions from certain entities if certain conditions are met
