FFIEC BSA/AML Infobase
In addition to the resources geared towards money services businesses available from FinCEN at www.MSB.gov, you may want to check out the “Bank Secrecy Act / Anti-Money Laundering Infobase” produced by the Federal Financial Institution Examination Council or FFIEC.
The Council is a formal interagency body empowered to prescribe uniform principles, standards, and report forms for the federal examination of financial institutions by the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Office of Thrift Supervision (OTS) and to make recommendations to promote uniformity in the supervision of financial institutions.
The FFIEC’s BSA infobase is really geared towards banks, credit unions and thrifts but can provide an MSB with great insight into how its bank will be audited and reviewed… and therefore, what it expects from its customers…including money services businesses. Higher risk MSBs, particularly money transmitters which are at greatest risk of having their banking services terminated, can learn much from the manual on how best to manage risk effectively.
The manual is available online and as a searchable download. Additionally, the FFIEC provides a presentation to watch over the Internet describing the requirements.
Click on the link for the BSA infobase at www.FFIEC.gov for access to the materials.
FinCEN’s FREE MSB Materials
The Financial Crimes Enforcement Network (FinCEN) has developed some training materials to help money services businesses better understand and comply with the Bank Secrecy Act.
The materials are provided to MSBs free of charge and can be ordered from the www.MSB.gov website maintained by FinCEN.
There are several pamphlets available in both English and in Spanish as well as a VHS video and video CD-ROM (also available in both English and in Spanish). Posters and “Take One” cards are also available in multiple languages.
The written materials provide good information for business owners and supervisors but aren’t ideal training materials. It would certainly be good for employees to read the documents though and a business could document that as part of its training program.
The video is pretty good as a tool to help your employees know and understand the basics.
Be sure to order a set of the materials for your business and to use them as part of your business’ ongoing training program.
Reading articles and participating in forum discussions on this website is also part of your training program and “counts” towards staying informed and becoming knowledgeable so as to appropriately address risks for your business.
This website, www.MoneyServicesBusiness.com, is a great website for you to learn and review some of the information needed to successfully manage risk and maintain a strong Bank Secrecy Act compliance program. Additional resources include those of national industry associations such as the National Money Transmitters Association (www.NMTA.us) and the Financial Service Centers of America (www.FISCA.org). Many of the states also have associations providing valuable information and support to money services businesses.
Please see the Resources tab for direct links to various associations.
IRS BSA Education and Outreach Team
IRS Teams Provide Education on Bank Secrecy Act Requirements
The Small Business and Self-Employed Operating Division of the Internal Revenue Service has a team of Bank Secrecy Act (BSA) Specialists that provides education to money services businesses (MSBs) on the reporting and recordkeeping requirements of the BSA. The BSA requirements may apply to you, your members, or clients.
Definition of an MSB
MSBs include any person conducting business of more than $1,000 with the same person on the same day in any one of the following activities: currency dealing or exchange; check cashing; issuing, selling or redeeming travelerâ€™s checks, money orders or stored value; or, provides money transfer services in any amount.
Each business that meets the definition of an MSB must register with the Department of the Treasury, except for the following:
1. A business that is an MSB solely because it serves as an agent of another MSB;
2. A business that is an MSB solely as an issuer, seller, or redeemer of stored value;
3. The U.S. Postal Service and agencies of the U.S., or any State, or of any political subdivision of any State;
4. A branch office of an MSB.
Other MSB Reporting Requirements
MSBs, except for check cashers and issuers, sellers, or redeemers of stored value, are required to file Suspicious Activity Reports. All MSBs are required to have anti-money laundering compliance programs and to file Currency Transaction Reports to report cash transactions of more than $10,000.
Sources for Additional Information
If you would like more information about the MSB reporting and recordkeeping requirements, please call the BSA specialist in your area (not toll-free). BSA specialists may provide seminars free of charge, if the requestor meets certain requirements.
Alex Basden: (212) 719-6764
ME, NH,VT, MA, CT, RI, NY, PA, NJ, DE, MD, Washington DC
Susan Vega: (954) 423-7777
VA, NC, SC, GA, FL, AL, MS, TN, AR, Puerto Rico
Theresa McGill: (630) 493-5190
WV, OH, KY, MI, IN, IL, MN, WI, IA, MO
Ulla Scott: (213) 576-3865
Los Angeles, S CA, NM, AZ, NV, UT, CO
Terri Malone: (510) 637-2621
N CA, WY, MT, ID, WA, OR, AK, HI
Cassandra Felton: (281) 721-7976
OK, LA, KS, NE, TX, ND, SD
You can find additional information about money laundering and the Bank Secrecy Act at FinCen or MSB website.