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Compliance Question of the Week
In today’s banking environment as soon as one big new regulation is implemented another pops up. Our compliance resources help your community bank stay one step ahead of the regulators.
If a customer meets the Phase I exemption criteria, is a bank prohibited from filing a CTR?
No. The exemption process is at the financial institution's discretion. This means, you may choose to forgo exempt designations and continue to report large currency transactions for every customer.
Reference: 31 CFR 1020.315(b).