FinCEN FAQs - Timely biennial renewal of the DEP form with respect to non-listed businesses and payroll customers:

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31 CFR § 103.22(d)(5)(ii) - Non-listed businesses and payroll customers - states “The designation of a non-listed business or a payroll customer as an exempt person must be renewed biennially, beginning on March 15 of the second calendar year following the year in which the first designation of such customer as an exempt person is made, and every other March 15 thereafter, on such form as FinCEN shall specify.”

FinCEN offers the following practical examples as a way of demonstrating the timely biennial renewal of the DEP form with respect to non-listed businesses and payroll customers:


Practical Examples
A) Initial DEP forms filed in February of 2001 are required to be renewed on or before March 15, 2003. Analysis - The initial designation was filed in calendar year 2001 (the base year), the first calendar year following the year in which the initial designation was made is 2002, the second calendar year following the year in which the initial designation was made is 2003, and the filing deadline within that second calendar year is March 15, 2003.

B) Initial DEP forms filed in June of 2001 are required to be renewed on or before March 15, 2003. Analysis - The initial designation was filed in calendar year 2001 (the base year), the first calendar year following the year in which the initial designation was made is 2002, the second calendar year following the year in which the initial designation was made is 2003, and the filing deadline within that second calendar year is March 15, 2003.

FinCEN’s Answers to BSA FAQs can be found here:  http://www.fincen.gov/statutes_regs/guidance/html/reg_faqs.html

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