CTR Exemption Annual Review Checklist

Annual compliance inspection for verifying that Phase I and Phase II Currency Transaction Report (CTR) exemptions remain valid for exempt customers and that supporting documentation is current.

Review Scope and Customer Identification

• Customer record and exemption file identified for annual review
• Exemption type confirmed as Phase I or Phase II
• Annual review period documented
• Reviewer confirmed customer legal name and account ownership match the exemption file

Phase I Exemption Eligibility

• Phase I customer still qualifies under the applicable exemption category
• Customer status changes reviewed for mergers, charter changes, ownership changes, or closure
• Current supporting documentation on file for Phase I exemption
• Any adverse findings or exceptions escalated to BSA/AML compliance

Phase II Exemption Eligibility

• Phase II customer continues to meet the applicable business relationship requirements
• Transaction activity reviewed for consistency with expected exempt activity
• Any cash transaction patterns indicate the exemption may no longer be valid
• Phase II supporting documentation and approval evidence are current
• Review notes capture any required reclassification or removal from exempt status

Documentation, Monitoring, and Recordkeeping

• Exemption file includes the most recent annual review date and reviewer name
• Monitoring evidence reviewed for the period under review
• Any missing documents or expired approvals identified
• Record retention requirements met for the exemption review file
• Corrective action owner and due date documented for any deficiencies

Final Disposition and Sign-Off

• Exemption remains valid with no unresolved deficiencies
• Exemption status updated if removal, suspension, or reclassification is required
• Reviewer comments summarize the annual determination
• Inspector signature