September 18, 2009; CTR Exemption Guidance
Posted by Anthony Demangone
Look at the date above. Does it ring any bells? That's the implementation deadline for the new International ACH Transaction (IAT) rules. Here's a good resource for you if ACH compliance is one of your responsibilities - NACHA's IAT webpage.
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FinCEN has released guidance to help credit unions and other financial institutions comply with CTR exemption requirements. Specifically, the guidance should help you determine what supporting information is suitable for determining what portion of a business member's annual gross revenues is derived from activities that are ineligible for CTR exemptions.  Read the press release and access the guidance here. Here's a snippet from the guidance.
The Financial Crimes Enforcement Network (FinCEN) is issuing this guidance to assist banks in determining the appropriateness of exempting from currency transaction reporting requirements non-listed business customers that derive some portion of their annual gross revenues from ineligible business activities.
Kudos to FinCEN. I've always thought that there isn't enough guidance on CTRs, while we are buried in SAR-related documents. I hope this signals a new trend.