Financial Crimes Enforcement Network
FinCEN DOEP | Form 110 - XML Schema 2.0 User Guide (v1.2 | August 2021) 54
9. Attachment C – Electronic XML Filing Instructions
The following instructions apply only to the electronic filing of the Designation of Exempt Person (DOEP) report,
FinCEN Form 110, through FinCEN’s BSA E-Filing System. These instructions do not apply to any other current or prior
Bank Secrecy Act reports.
General Information
The Bank Secrecy Act and its implementing regulations require banks to file currency transaction reports on
transactions in currency of more than $10,000. The regulations also permit a bank to exempt certain customers from
currency transaction reporting in accordance with 31 CFR 1020.315.
Banks are the only type of financial institutions that may exempt customers from CTR filing requirements. The term
bank is defined in 31CFR 1010.100(d); and includes savings and loan associations, thrift institutions, and credit unions.
The customers that the bank may exempt are called “exempt persons.” An exempt person may be a bank,
government agency/government authority, listed company, listed company subsidiary, eligible non-listed business, or
payroll customer.
A bank may, but is not required to, use this report to notify the Treasury that the bank has revoked the designation of
a customer as an exempt person.
FinCEN encourages banks to use the exemption procedure to the fullest extent. FinCEN reminds banks of their
continuing obligation to monitor for and report suspicious activity with respect to transactions of all customers,
including currency transactions conducted by exempt persons.
General Instructions
1. Filing: The DOEP should be e-filed through the BSA E-Filing System. Go to
http://bsaefiling.fincen.treas.gov/index.jsp to register. Any bank that wishes to designate a customer as an
exempt person must file the DOEP no later than 30 days after the first transaction to be exempted.
2. Report Completion. Complete the report in accordance with instructions for each item. Unless there is a specific
instruction to the contrary, leave blank any items that do not apply.
3. Dates. Discrete DOEP filers must enter dates in MM/DD/YYYY format with MM = month, DD = day, and YYYY =
year. Single digit months and days must begin with a zero. Batch filers must enter dates in YYYYMMDD format.
4. Numbers. Enter all numbers such as identifying and telephone numbers as single number strings without
formatting or punctuation such as spaces, hyphens, or parenthesis.
5. Addresses. Enter the permanent street address, city, two-letter state or territory abbreviation, and ZIP Code.
Provide the apartment number or suite number, if known, following the street address. A non-location address
such as a post office box or rural route number should be used only if no other street address information is
available. ZIP Codes must be five or nine digits. ZIP Codes must be entered without formatting or special
characters such as hyphens. For example, the ZIP Code 12354-6120 would be entered as 123546120. Complete
any address item that is known, even if the entire address is unknown. No abbreviations are permitted in city
names, which must be completely spelled out. A U.S. city name should match the city name used by the U.S.
Postal Service for the associated state and ZIP Code. Use only the authorized U.S. Postal Service state, territory, or
military address abbreviations found at https://www.usps.com/ship/official-abbreviations.htm. When a
Transmitter address involves a U.S. Territory the both state and country items elements must contain the U.S.
Territory code as found in ISO 3166-1. Foreign batch filers who are completing the Transmitter Address element
with foreign address information must use only the Canadian and Mexican state/territory/province codes and ISO
country codes approved for use by FinCEN. For Canadian provinces and territories use the Canada Post
Corporation codes found at http://www.canadapost.ca/tools/pg/manual/PGaddress-e.asp#1380608. For Mexican
states and territories use the ISO 3166-2 three-letter codes found at
http://www.commondatahub.com/live/geography/state_province_region/iso_3166_2_state_codes. For all