IBA Compliance Connection

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Do you have an example or template of a request for exceptive relief that we can use to request relief from FinCEN for backfiling Currency Transaction Reports (CTRs) involving Thillens (a registered money services business) replenishing our ATMs? FinCEN stated to us that we need to send in a specific request for exceptive relief from backfiling CTRs on these transactions. Additionally, may I share this letter with other individuals?

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A member of our Compliance Division Advisory Committee received a sample letter to FinCEN from Thillens for the purposes of requesting exceptive relief from backfiling CTRs related to their transactions with Thillens. If you choose to use it as a template, we recommend reviewing it carefully, as not all information may pertain to your bank.

Additionally, we ask that distribution of the letter be limited to IBA members. Please ask any individuals you know who are interested in receiving a copy of the letter to contact us so that we can determine whether they are IBA members before distributing.