BSA FAQs 16 - When a federal, state or local government official, as part of his or her official duties, engages in a transaction in currency over $10,000, what identifying information must be obtained?

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Q:  When a Federal, state or local government official, as part of his or her official duties, engages in a transaction in currency over $10,000, or purchases a monetary instrument for more than $3,000 in currency, as a non-accountholder, what kind of identifying information must a financial institution obtain?
 
A:  Government officials sometimes need to conduct large currency transactions as part of their official duties. For example, a law enforcement official may wish to convert seized currency into monetary instruments for security reasons. Banks are not required to file a CTR when a Federal, state or local government official, as part of his or her official duties, engages in a transaction in currency over $10,000. In addition, banks do not need to file a Designation of Exempt Person form (FinCEN Form 110) for customers that are a department or agency of the United States, of any State, or of any political subdivision of any State. A bank should, however, take the steps to ensure that the customer is eligible for the exemption (that the customer is a government official conducting business on behalf of a government agency) and document the basis for that determination (e.g., reviewing the customer’s law enforcement credentials or government photo ID).

Notwithstanding the above, a financial institution should still obtain and record the name of the government official conducting the transaction. Regarding the purchase of a monetary instrument for more than $3,000 in currency, a financial institution should record the name and date of birth of the government official, for the financial institution’s records. (12/2017)

ADDITIONAL INFORMATION:
This FAQ was obtained from FinCEN’s website, in the section for Answers to Frequently Asked BSA Questions, which may be found here: 

https://www.fincen.gov/answers-frequently-asked-bank-secrecy-act-bsa-questions

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