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Exempt Person

Compliance Risk and ControlsUpdated 15 Nov 2026

In the US anti-money laundering framework, an exempt person is a customer that a bank has formally designated as exempt from filing a currency transaction report (CTR), which is otherwise required for cash transactions above 10,000 US dollars. The rules, made under the Bank Secrecy Act and administered by FinCEN, allow exemptions for low-risk customers such as other banks, government agencies, listed companies and their subsidiaries, and, subject to conditions, certain established non-listed businesses and payroll customers.

Banks designate exempt persons by filing a designation with FinCEN and must review eligibility periodically. Exemption covers CTR filing only: banks must still monitor the customer and file a suspicious activity report where warranted. In other contexts the phrase has different meanings; under UK financial services law, for example, an exempt person is a firm allowed to carry on certain regulated activities without authorisation.

Last updated 15 Nov 2026