Before I start my annual CTR exemption review i want to be sure I've got the new rules correct.

New customer (3-months)at the bank. Exemtible-type business (buffet/restaurant). Has completed 2 transactions over $10,000) in the first 3-months. The bank believes they will have large cash needs of at least 5 times during 2009.
1. May we exempt them now????
2. Is the 5 times in a 12-month period test only come into play during the annual review (which is obviously still required)?

Thnaks in advance for any responses

Ok, ok, one more question.......
3. Is the March 15th still the required date by which we should be completing our annual reviews?

I think you have to wait until you've filed the 5 CTRs on them. Otherwise you have to do a risk based assessment.

When I read the guidance, I don't see anything that gives us a 3/15 deadline for review. That said, if you've been reviewing your exempt customers annually (as required), it seems logical to keep to the same schedule.

You can exempt them now, but you must do a risk-based assessment for at least two months and it must be documented. Based on the assessment, you should be able to form a reasonable belief that the client has a legitimate business purpose for conducting the transactions.