First National Bank has several exempt customers.
" Alpha is an exempt person because its stock is listed on a major stock exchange.
" Beta is an exempt person because it meets the nonlisted customer requirements.
" Zeta is exempt because it is a payroll customer. For which customer(s) must the bank conduct an annual review to determine its continuing eligibility to be exempt from CTR filings?
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A. B. C. D.D
The Currency Transaction Report (CTR) is a report that financial institutions are required to file with the Financial Crimes Enforcement Network (FinCEN) for certain currency transactions. However, there are certain customers who are exempt from CTR filings. These exemptions are granted based on specific criteria established by FinCEN.
In this scenario, First National Bank has three exempt customers: Alpha, Beta, and Zeta. Alpha is exempt because its stock is listed on a major stock exchange, Beta is exempt because it meets the nonlisted customer requirements, and Zeta is exempt because it is a payroll customer.
The question asks for which customer(s) the bank must conduct an annual review to determine its continuing eligibility to be exempt from CTR filings. This means that the bank needs to review each customer's exemption status annually to ensure that they still meet the criteria for exemption.
According to the information given, Alpha, Beta, and Zeta are all exempt customers. However, the criteria for their exemption are different.
Alpha's exemption is based on the fact that its stock is listed on a major stock exchange. This exemption is granted automatically and does not require any additional review or verification by the bank. Therefore, the bank does not need to conduct an annual review for Alpha.
Beta's exemption is based on the fact that it meets the nonlisted customer requirements. These requirements include having an established business relationship with the bank, maintaining a transaction account, and having a physical presence in the United States. Since Beta's exemption is based on these criteria, the bank must conduct an annual review to ensure that Beta still meets these requirements.
Zeta's exemption is based on the fact that it is a payroll customer. Payroll customers are exempt from CTR filings for transactions related to payroll processing. Since Zeta's exemption is based on this specific activity, the bank must conduct an annual review to ensure that Zeta is still using its account for payroll processing and still meets the criteria for exemption.
Therefore, the answer to the question is D. The bank must conduct an annual review for both Beta and Zeta to determine their continuing eligibility for exemption from CTR filings.