BSA Phase I exempt customer

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Question:

I have a BSA question about Phase I exempt customers. I know that Phase II customers' savings accounts can't be exempted, but what about Phase I customer savings accounts? At my institution we have a government entity but they only hold savings accounts with us. Would they still be considered Phase I exempt in our institution at all? And if so, would we have to perform a yearly review on them?

Answer:

by Randy Carey: All transactions with a Phase I customer are covered by the exemption. Only non-listed business are limited to transactions in or out of their transaction or money market savings accounts (1020.315(e)(9)). A governmental agency is not subject to an annual review (1020.315(d)).

Answer:

by Ken Golliher: In full agreement, but to say the same thing differently: It is wrong to file a CTR on a government entity. Any reviewer could justifiably criticize your bank's 1) training and 2) internal controls.