GENERAL ANTI-MONEY LAUNDERING PROGRAM REQUIREMENTS

• Types of Money Services Businesses
• MSB Registration Requirements
• Risk-Based BSA/AML Program
• Compliance Officer
• Independent Testing of Internal Compliance

REPORTING RESPONSIBILTIES

• Currency Transaction Reporting
• Sales of Monetary Instruments
• Suspicious Activity Reporting
• Reports of Transportation of Currency or Monetary Instruments
• Reports of Foreign Financial Accounts
• Reports of Transactions with Foreign Financial Agencies
• IRS Reporting

RECORDKEEPING RESPONSIBILITIES

• Funds Transmittal Recordkeeping
• Additional Recordkeeping Requirements for Currency Dealers and Exchangers

CUSTOMER IDENTIFICATION PROGRAM (CIP)

OFAC COMPLIANCE

BSA TRAINING PROGRAM

INFORMATION SHARING WITH GOVERNMENT AGENCIES

NATIONAL SECURITY LETTERS

DEFENSE DEPARTMENT AUTHORITY TO OBTAIN INFORMATION

INFORMATION SHARING WITH OTHER FINANCIAL INSTITUTIONS

OBTAINING BANKING SERVICES

PREPARING FOR EXAMINERS

Money services businesses are highly diverse and have, until recently been rather under-regulated in the opinion of many experts on money laundering. Nevertheless, the substantial amount of regulation in the area that has been released in recent years justifies a checklist for money services businesses, and such businesses should be able to satisfactorily deal with all the issues raised in the checklist provided here

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