DOEP FAQs - Is a customer that has been the subject of a Suspicious Activity Report ("SAR") eligible for initial or continued exemption?

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Q:  Is a customer that has been the subject of a Suspicious Activity Report ("SAR") eligible for initial or continued exemption?
 
A:  A Bank is required to file a SAR, where appropriate, regarding the activities of any of its exempt customers.17 However, if an exempt person is involved in a transaction that has been reported in a SAR, the bank is not required to cease treating the person as exempt. The decision to exempt, or to retain or revoke a customer's exemption, should be made by the bank in accordance with its risk-based anti-money laundering policies, procedures, and controls.
 
 
ADDITIONAL INFORMATION:
This FAQ was obtained from FinCEN’s issuance FIN-2012-G003 – Guidance on Determining Eligibility for Exemption from Currency Transaction Reporting Requirements, which may be found here: 
 

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