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Frequently Asked Questions

What is an AML Program?

An AML Program is a set of policies and procedures that prevent money laundering and financing terrorist activities. AML is an acronym for “anti-money laundering.” A Money Services Business (MSB) must develop and implement a customized AML Program for their money services.

Why do I need an AML Program?

As part of the Bank Secrecy Act of 1970 (BSA) and USA PATRIOT Act of 2001, all money services businesses (MSB) must develop and implement policies and procedures that prevent money laundering and financing terrorist activities. Financial institutions must ensure that their MSB customers have effective AML Programs. If you do not have an AML Program, you will not be able to open a money service business account with a bank.

I have 10 locations; do I need an AML Program for each location?

You might need multiple BSA/AML/OFAC Programs based on your corporate structuring. Contact us regarding your specific needs.

I received a letter from my bank, what should I do?

If you have received a letter like this from your bank, time is of the essence. If you do not already have one, you will need an AML Program and/or Third Party Independent Review. It is important that you begin to work on this matter immediately to ensure your continued relationship with your bank. CCE has developed strong relationships with many banks and are confident we can satisfy your bank’s requirements. Many businesses lose their bank accounts as a result of not responding to these letters in a timely manner. Please contact us so that we can begin assisting you.

What is a Third Party Review?

As part of the Bank Secrecy Act of 1970 (BSA) and USA PATRIOT Act of 2001, all money services businesses (MSB) are required to establish an independent audit function to test their AML Programs. Banks typically require MSBs to have a third party independently review their AML Program. This review will ensure that policies, procedures, internal controls, record keeping, reporting functions and training are sufficient. It will also identify any deficiencies and present an opportunity to amend them. A “third party” is a qualified professional, accounting firm, or outside consultant, like Capital Compliance Experts, to perform the review.

Can Capital Compliance Experts help my business with a Third Party Review?

Yes. Our team is comprised of CAMS certified professionals that have extensive experience in BSA rules and regulations for both large and small businesses. Contact us for a quote today.

Is Capital Compliance Experts CAMS Certified?

Yes, our compliance specialists are CAMS certified. The Association of Certified Anti-Money Laundering Specialists (ACAMS) is the largest international AML and financial crime prevention community. ACAMS accreditation is a Certified Anti-Money Laundering Specialist (CAMS). These credentials identify those who earn it as possessing specialized AML knowledge.

What is a "CTR"?

A CTR is a Currency Transaction Report. MSBs are required to file CTRs for each transaction, or group of transactions in a 24 hours period, that result in cash in or cash out of more than $10,000. CTRs must be filed electronically through the BSA E-Filing System. Our software enables you to file CTRs directly to FinCEN.

What is a "SAR"?

An SAR is a Suspicious Activity Report. Certain MSBs are required to file SARs for any transaction that is both suspicious and over $2,000. A transaction is suspicious if the MSB has reason to believe that the transaction involves funds from an illegal activity, is designed to evade requirements of the Bank Secrecy Act (BSA) or serves no apparent lawful business. SARs must be filed electronically through the BSA E-Filing System. Our software enables you to file SARs directly to FinCEN.

How do I file a CTR/SAR?

All CTRs and SARs must be filed electronically through FinCENs BSA E-Filing System. CTRs must be filed within 15 days of the transaction date and SARs must be filed within 30 days of the transaction date. Many check cashing software systems include CTR/SAR filing options. Our software enables you to file CTRs and SARs directly to FinCEN.

Is my business an "MSB"?

A Money Services Business (MSB) is a business that transmits or converts money in one or more of the following capacities: :

  • Check casher
  • Money transmitter
  • Provider or seller of prepaid access
  • Seller or redeemer of traveler’s checks or money orders
  • Issuer of traveler’s checks or money orders
  • Dealer in foreign exchange
  • U.S. Postal Service

As an MSB you must comply with the BSA requirements applicable to financial institutions and the specific requirements applicable to MSBs.

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Do my employees need AML training?

All employees involved in the handling of money services activity must be trained to understand BSA requirements as they relate to the business. Specifically, they must know the contents of the company’s BSA/AML/OFAC Program. This includes (but not limited to): customer identification and verification procedures, SAR and detection, understanding structured transactions, CTR and thresholds, and additional record keeping requirements regarding money transfer and money order transactions. Visit On POinT Training Center for 70+ industry specific courses to choose from.

What is a Compliance Officer?

A Compliance Officer is an individual appointed by a company to:

  • Monitor the compliance of AML obligations;
  • Oversee the communication and training for employees;
  • Ensure that the company keeps and maintains all required AML records;
  • Be knowledgeable about the BSA and all related regulations; and
  • Understand the company’s services and products and the potential money laundering and terrorist financing risks associated with those activities.
What is a Risk Assessment?

A Risk Assessment provides a clear basis for developing the MSBs policies and procedures. Every MSB poses a set of risks based off of their location, business size and the nature and volume of financial services offered. Knowing the risks, you can design the proper policies and procedures needed to mitigate loss, money laundering and financing terrorist activities.

What are my licensing/registration requirements?

All MSBs must register with FinCEN and renew their registration every two years before Dec. 31st. Changes in ownership require a new registration. Criminal and civil penalties may be imposed for a violation of this registration requirement. A business that never conducts transactions over $1,000 for one person during a single business day is not required to register as an MSB. Business licensing and permit requirements are dependent on the state laws of your business location. Please contact us to assess your licensing and registration requirements.

How do I register as an MSB?

MSB registration is the responsibility of the owner or controller and must be filed within 180 days of the establishment date. MSB Registration must be filed electronically through the BSA E-Filing System. Please contact us for assistance in registering with FinCEN.

Are Financial Service Centers regulated? If so, by whom?

Yes. MSBs are considered financial institutions and must comply with BSA requirements. Financial institutions are subject to examination by the Internal Revenue Service (IRS). Financial institutions must also adhere to state laws and regulations in the majority of jurisdictions, including the proper licensing and registration. Financial institutions that offer payday loans must also comply with additional regulations such as those implemented by the Consumer Financial Protection Bureau (CFPB). Contact us if you have any questions regarding the specific guidelines for your business.

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