Anti-Money Laundering

General Information

Money Laundering Prevention
http://www.msb.gov/pdf/msb_prevention_guide.pdf

Bank Secrecy Act Requirements
http://www.msb.gov/pdf/bsa_quickrefguide.pdf

Reporting Suspicious Activity
http://www.msb.gov/pdf/msbsar_quickrefguide.pdf

Order Form for Free materials to help Money Services

Businesses understand and comply with new federal laws

and regulations
http://www.msb.gov/pdf/msborderform.pdf

AML Training for Staff: Your First Line of Defense

(May/June 2003, ABA Bank Compliance)
 

FinCEN Form 107 - Registration of Money Services

Business
http://www.fincen.gov/msbregform01102005.pdf

TD F 90-22.56 - Suspicious Activity Report by Money Services Business
http://www.fincen.gov/f902256.pdf

FinCEN Form 104 - Currency Transaction Report
http://www.fincen.gov/fin104_ctr.pdf

Anti-Money Laundering Compliance Program Form
http://www.willinghamcote.com/mlc/AMLprogram_0205.pdf

As a provider of money services such as money orders, traveler’s checks, money transfers, check cashing, currency exchanges and stored value services (such as prepaid gift cards), it is important that the company and each of its employees understand the obligations to help prevent money laundering, and the duty to comply with certain reporting and record keeping requirements imposed on the company by federal law. In order to protect the company and its employees from being taken advantage of or used as a source for illegal money laundering, the company and its employees need to know how money laundering schemes operate and how to identify possible money laundering activities.

Money Laundering is the attempt to “launder” or conceal illegal activity, including the crimes that generate the money itself, such as drug trafficking. Money laundering conceals the source of illegal money so the money can be used without detection of its criminal source. Financial institutions, including money services businesses (MSBs) have been both willing and unwilling participants in money laundering activities. Criminals use businesses to hide or disguise the origin of money that comes from illegal activities.

Businesses that conduct some or all of these activities must comply with all anti-money laundering laws and regulations or suffer the consequences. These requirements include the need to register with the U.S. Department of Treasury, adopting an anti-money laundering program, appointing a Compliance Officer to manage the program, provide annual employee anti-money laundering training, and filing “Suspicious Activity Reports” and “Currency Transaction Reports” as well as retaining a transactions “Log” and records of suspicious transactions. Each of these requirements have specific criteria to determine when and how to satisfy these requirements. Failure to satisfy the requirements could result in severe penalties and it is important for the company and its employees to become familiar with the requirements and seek advice from legal counsel to ensure that the requirements are complied with.

To fully understand the requirements, it is important each company that is a provider of money services review the Anti-Money Laundering Compliance Program guide.  A copy of this guide should be provided to each employee that will be involved in any regulated money service and each employee should review and understand these requirements.
 

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333 Albert Ave., Ste. 500, East Lansing, Michigan 48823

(517) 351-6200