Glossary

A person or business authorized to provide money services on behalf of an MSB under an agreement with the MSB. Agents may perform services such as money transmission, check cashing, or selling money orders, depending on the arrangement. An MSB remains responsible for complying with applicable BSA requirements for its agents.

The ongoing oversight of an MSB’s agents to ensure they follow applicable laws, regulations, policies, and procedures. This may include transaction reviews, compliance testing, training, risk assessments, and monitoring for suspicious activity.

The Agent Trust Agreement is the contract between the principal MSB and a company agreeing on terms of being an agent for MSB services.

An Agent Verification letter is a formal document that confirms an individual or business entity is authorized to act on behalf of another party.

The process of combining multiple transactions involving the same customer, person, entity, or related parties to identify activity that may exceed regulatory thresholds or present a heightened risk.

The Anti-Money Laundering Act of 2020 (AMLA) is the most comprehensive update to the U.S. Bank Secrecy Act (BSA) in decades. It overhauls the nation's financial regulatory architecture to combat money laundering, terrorist financing, and illicit financial activity by modernizing compliance programs and increasing transparency.

An AML/CFT program is a comprehensive risk-based BSA policies and procedures that financial institutions and regulated businesses use to prevent, detect, and report illicit financial activity.

Anti-Money Laundering (AML) is the framework of laws, regulations, and controls designed to prevent criminals from disguising illegally obtained funds as legitimate income.

Individuals or businesses authorized by a money transmitter to provide money transmission services on its behalf. The term is commonly used in state money transmission laws and may have specific requirements depending on the jurisdiction.

The Bank Secrecy Act (BSA), enacted in 1970, is a federal law that requires financial institutions and certain businesses to maintain records and report specific transactions to the U.S. Department of the Treasury. These requirements help law enforcement detect, investigate, and prevent money laundering, terrorist financing, and other financial crimes.

An individual who ultimately owns or controls a legal entity, or exercises ultimate effective control over it. Identifying beneficial owners helps financial institutions understand who ultimately controls or benefits from a customer relationship.

A decentralized digital currency that operates on a blockchain and allows value to be transferred electronically without relying on a central issuing authority. Bitcoin is a type of cryptocurrency and may be subject to AML/CFT and other regulatory requirements depending on how it is used.

The illegal movement of large quantities of currency or monetary instruments across a border with the intent to evade currency reporting or other legal requirements.

The California Consumer Privacy Act (CCPA) is a state privacy law that provides California residents with rights over their personal information and requires covered businesses to be transparent about how they collect, use, share, and protect consumer data. The law helps safeguard consumer privacy and promotes responsible data management practices.

The process of documenting, investigating, tracking, and resolving compliance alerts, investigations, and cases, including those involving suspicious or unusual activity.

A business that, for a fee or other consideration, accepts checks or other monetary instruments in exchange for currency or other value. Under federal BSA regulations, a person generally falls within the MSB check-casher definition when it cashes more than $1,000 for any one person on any one day.

A Compliance Management System (CMS) is a structured program designed to help an organization comply with regulatory requirements, including AML/CFT, BSA, OFAC, consumer protection, and state licensing regulations. The CMS establishes the controls, processes, and oversight necessary to identify compliance risks, monitor activities, train employees, and maintain ongoing regulatory compliance.

A Compliance Officer or BSA/AML Compliance Officer is the individual responsible for overseeing and managing an organization's AML/CFT program.

A Compliance Resource Officer (CRO) is a compliance professional who supports the implementation, administration, and ongoing effectiveness of an organization's AML/CFT compliance program. Working under the direction of the BSA/AML Compliance Officer or Compliance Manager, the Compliance Resource Officer helps ensure regulatory requirements are met by assisting with customer due diligence, transaction monitoring, sanctions screening, regulatory reporting, recordkeeping, employee training, and compliance documentation.

The Consolidated Canadian Autonomous Sanctions List is Canada's official list of sanctioned persons and organizations that businesses must screen against to avoid engaging in prohibited transactions or activities.

The Consolidated Omnibus Budget Reconciliation Act (COBRA) is a federal law enacted in 1985 that allows eligible employees, former employees, spouses, former spouses, and dependent children to temporarily continue their employer-sponsored health insurance coverage after certain qualifying events, such as job loss, reduction in work hours, divorce, or the death of a covered employee.

Convertible virtual currency (CVC) is a type of virtual currency that has an equivalent value in real currency or acts as a substitute for real currency. CVC can be digitally exchanged, transferred, or used to purchase goods and services.

A bank that provides financial services to another bank or financial institution, such as facilitating payments, wire transfers, clearing, or access to financial networks.

Relationships in which one financial institution provides banking or financial services to another financial institution, often involving payment processing, clearing, settlement, or access to financial services.

Countering the Financing of Terrorism (CFT) is the framework of laws, regulations, and controls designed to prevent terrorists and terrorist organizations from raising, moving, storing, or using funds to support their activities.

A form of digital or virtual currency that uses cryptography and generally operates on distributed ledger or blockchain technology. Cryptocurrencies can be used to transfer or store value and may present unique AML/CFT risks.

A Currency Transaction Report (CTR) is a report filed by a financial institution for cash transactions exceeding $10,000 in a single business day. CTRs help government agencies monitor large cash transactions and combat money laundering and other financial crimes.

Customer Due Diligence (CDD) is the process financial institutions use to identify and verify the identity of customers, understand the nature and purpose of customer relationships, and assess the risk that customers may pose for money laundering, terrorist financing, or other illicit activities. CDD helps institutions develop a risk profile for each customer and apply appropriate monitoring and controls throughout the relationship.

A Customer Identification Program (CIP) is the process used to verify a customer's identity before providing financial services, helping institutions know who their customers are and preventing money laundering, terrorist financing, and other financial crimes.

The practice of terminating or restricting relationships with customers, businesses, products, or geographic areas considered to present elevated financial crime or compliance risk, rather than managing the risk through appropriate controls.

The individual assigned responsibility for day-to-day oversight of an MSB's AML program.

The process of gathering and evaluating information necessary to understand and manage customer, agent, counterparty, product, or geographic risk.

The illegal or improper use of an older person's money, property, or financial resources for another person's benefit. Financial institutions may identify and report transactions or activity indicating potential elder financial exploitation.

The Electronic Funds Transfer Act (EFTA) is a federal law that establishes the rights, responsibilities, and protections of consumers who use electronic methods to transfer funds. Enacted in 1978 and implemented through Regulation E, the EFTA governs electronic transactions such as debit card purchases, ATM withdrawals, direct deposits, electronic bill payments, and other electronic fund transfers.

The Electronic Signatures in Global and National Commerce Act (E-SIGN Act) is a federal law enacted in 2000 that gives electronic signatures and electronic records the same legal validity and enforceability as handwritten signatures and paper documents in most business and consumer transactions.

Enhanced Due Diligence (EDD is the process of taking additional and more in-depth measures to identify, verify, and understand a customer and the risks they may pose for money laundering, terrorist financing, or other financial crimes.

The Equal Credit Opportunity Act (ECOA) is a federal law that prohibits creditors from discriminating against applicants in any aspect of a credit transaction. Under the ECOA, lenders must evaluate credit applicants based on their creditworthiness and ability to repay, rather than on protected characteristics.

The Expedited Funds Availability Act (EFAA) is a federal law that establishes rules for how quickly banks must make deposited funds available to customers. The law was enacted to ensure consumers have timely access to funds deposited into transaction accounts and to promote consistency in funds availability practices among financial institutions. Implemented through Regulation CC, the EFAA sets maximum hold periods for certain types of deposits, outlines when banks may delay the availability of funds, and requires financial institutions to disclose their funds availability policies to customers.

The Fair and Accurate Credit Transactions Act (FACTA) helps protect consumers from identity theft and inaccurate credit reporting by strengthening credit reporting rules and requiring businesses to safeguard consumer information.

The Fair Credit Reporting Act (FCRA) is a federal law that regulates how consumer reporting agencies collect, use, and share consumer credit information. The law is designed to promote the accuracy, fairness, and privacy of information contained in consumer reports and to ensure that consumer information is used only for legitimate purposes.

The Fair Debt Collection Practices Act (FDCPA) is a federal law that regulates the conduct of third-party debt collectors and protects consumers from abusive, deceptive, and unfair debt collection practices. The law establishes standards for how and when debt collectors may communicate with consumers and prohibits harassment, false statements, threats, and other improper collection tactics.

The Fair Labor Standards Act (FLSA) is a federal law that establishes minimum wage, overtime pay, recordkeeping, and child labor standards for employees in the private sector and in federal, state, and local governments. The law is designed to protect workers by setting basic employment standards related to wages and hours worked.

An alert generated by a monitoring or screening system that initially appears to indicate potentially suspicious or prohibited activity but, after review, is determined not to represent a genuine compliance concern.

The Family and Medical Leave Act (FMLA) is a federal law that provides eligible employees of covered employers with up to 12 weeks of unpaid, job-protected leave in a 12-month period for certain family and medical reasons. Qualifying reasons may include the birth or adoption of a child, caring for a spouse, child, or parent with a serious health condition, or the employee’s own serious health condition.

The Financial Crimes Enforcement Network (FinCEN) is the bureau of the U.S. Department of the Treasury responsible for safeguarding the financial system from money laundering, terrorist financing, and other financial crimes. FinCEN accomplishes this through the administration of the Bank Secrecy Act (BSA) and the collection, analysis, and dissemination of financial intelligence.

FINTRAC is Canada's national financial intelligence unit, established to help detect, prevent, and deter money laundering, terrorist activity financing, and other threats to the security of the country.

The Foreign Corrupt Practices Act (FCPA) is a federal law that prohibits U.S. companies, individuals, and certain foreign issuers from bribing foreign government officials to obtain or retain business or secure an improper advantage. The law also requires certain companies to maintain accurate books and records and implement internal accounting controls to help prevent corruption and concealment of improper payments.

Money services businesses located outside the United States that provide services such as money transmission, currency exchange, or other regulated financial services. Depending on their activities and U.S. connections, foreign MSBs may create additional geographic, correspondent, or AML/CFT risks.

A Fractional Compliance Officer is an experienced compliance professional who provides part-time, outsourced, or contract-based oversight and management of an organization's AML/CFT compliance program. Rather than serving as a full-time employee, a Fractional Compliance Officer performs the duties of a Compliance Officer on a flexible basis, helping organizations meet regulatory requirements while controlling costs.

A transaction in which funds are transmitted from one person or location to another through a financial institution or other intermediary. Under the federal Funds Travel Rule, certain transmittals of funds of $3,000 or more are subject to specific information requirements.

A Gap Analysis is a review of an organization’s AML/CFT program to identify weaknesses, missing controls, or areas where current practices do not fully meet regulatory requirements, industry standards, or the organization’s risk profile. The purpose of a gap analysis is to compare the institution’s existing AML/CFT program against applicable laws, regulations, guidance, and best practices in order to determine where improvements are needed.

The General Data Protection Regulation (GDPR) is an European Union (EU) privacy law that gives individuals more control over their personal data and requires organizations to handle that data lawfully, transparently, and securely.

The level of money laundering, terrorist financing, sanctions, fraud, corruption, or other financial crime risk associated with a particular country, region, or location.

A geographic targeting order (GTO) is a temporary order (180 days that can be renewed) issued by FinCEN that requires certain financial institutions or businesses in designated geographic areas to collect and report additional information about specified transactions when FinCEN determines the area or activity presents particular money laundering risks.

The Gramm-Leach-Bliley Act (GLBA) is a federal law that requires financial institutions to protect the privacy and security of consumers’ nonpublic personal information. The law also requires covered institutions to explain their information-sharing practices and provide customers with certain privacy notices and the opportunity to opt out of certain information sharing with nonaffiliated third parties.

The Health Insurance Portability and Accountability Act (HIPAA) is a law that protects the privacy and security of medical and health information and sets rules for how that information must be handled and safeguarded.

A high intensity financial crime area (HIFCA) is a geographic area designated by the U.S. government as having a high level of money laundering or related financial crime activity and therefore requiring increased attention and resources to combat financial crime.

A customer whose characteristics, activities, transactions, geographic connections, or other factors indicate a higher-than-normal risk of money laundering, terrorist financing, fraud, or other illicit activity.

A high intensity drug trafficking area (HIDTA) is a geographic area designated by the Office of National Drug Control Policy as having significant drug trafficking activity. HIDTA designations may be considered as one factor when evaluating geographic financial crime risk.

The exploitation of people through force, fraud, or coercion for purposes such as forced labor or commercial sex. Financial activity associated with trafficking can present significant AML/CFT risks and may be identified through transaction monitoring and suspicious activity reporting.

The process of confirming that information provided by a customer or other individual is accurate and belongs to that individual. Verification may involve government-issued identification, databases, documentary evidence, or other reliable sources.

Financial activity involving money or other assets connected to illegal activity, including money laundering, terrorist financing, fraud, corruption, sanctions evasion, trafficking, and other financial crimes.

The independent review assesses the level of money laundering risk for an organization and provides a fair and unbiased opinion of the AML/CFT program. The objective is to ensure the program meets all requirements of the BSA.

Policies, procedures, systems, and processes designed to identify, prevent, detect, and mitigate compliance and financial crime risks and ensure that an organization operates according to applicable laws and its own requirements.

Risk arising from conducting transactions involving countries, states, territories, or regions associated with elevated financial-crime, sanctions, corruption, or regulatory concerns.

The risk associated with operating in, providing services to, or conducting transactions involving a particular legal jurisdiction based on factors such as regulatory environment, sanctions, corruption, financial crime, or AML/CFT controls.

Know your business (KYB) is the process of identifying and verifying a business customer and understanding its ownership, control structure, business activities, source of funds, and expected transactions. KYB helps organizations assess and manage the risks associated with business relationships.

Know Your Customer (KYC) is the process financial institutions use to verify the identity of their customers, understand the nature and purpose of the customer relationship, and assess the risk that the customer may pose for money laundering, terrorist financing, fraud, or other illicit activity. KYC is a foundational part of an organization’s AML/CFT program and helps ensure that institutions know who they are doing business with and can identify unusual or suspicious activity.

Know your customer's customer (KYCC) is the process of understanding and assessing the customers or end users of a business customer, particularly when the nature of the relationship creates indirect AML/CFT risk. KYCC may help an MSB understand who ultimately uses its services and identify potential financial crime risks within the customer’s customer base.

A Large Cash Transaction Report (LCTR) is a report that certain Canadian reporting entities must submit to FINTRAC when they receive CAD $10,000 or more in cash in a single transaction, or when they receive multiple cash transactions totaling CAD $10,000 or more within a 24-hour period that are conducted by, on behalf of, or for the same person or entity.

A formal request from a law enforcement agency for information, records, or assistance relating to a person, transaction, account, or investigation. Financial institutions may have specific obligations regarding how such requests are handled.

The second stage of traditional money laundering in which illicit funds are moved through multiple transactions, accounts, institutions, jurisdictions, or financial instruments to obscure their origin and make them more difficult to trace.

The Military Lending Act (MLA) is a federal law that provides financial protections to active-duty service members, their spouses, and certain dependents when they obtain consumer credit. The law is designed to protect military families from unfair or abusive lending practices and to ensure that covered loans are offered on fair and transparent terms.

Ministerial Directive Requirements are obligations issued by the Canadian Minister of Finance under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) that require reporting entities to apply specific countermeasures to financial transactions involving designated foreign jurisdictions or entities that present heightened money laundering or terrorist financing risk.

The Model Money Transmission Modernization Act (MTMA) is a model state law developed by the Conference of State Bank Supervisors (CSBS) to create a more uniform and modern regulatory framework for licensing, supervising, and regulating money transmitters across the United States. The MTMA establishes a consistent set of standards for areas such as licensing, net worth, surety bonds, permissible investments, and other prudential and compliance requirements applicable to money transmission businesses.

A financial instrument that represents or can be converted into monetary value, such as certain checks, drafts, money orders, and similar instruments.

A monetary instrument log is a record used by certain financial institutions or MSBs to document the issuance or sale of specified monetary instruments within applicable regulatory thresholds. The log generally captures information needed to support BSA recordkeeping and transaction monitoring requirements.

The process of concealing the source, ownership, movement, or control of proceeds derived from criminal activity in order to make those proceeds appear legitimate.

The Money Laundering Control Act of 1986 (MLCA) is a federal law that made money laundering a distinct federal crime in the United States. The law prohibits knowingly engaging in financial transactions involving proceeds derived from criminal activity, particularly when the purpose is to conceal the source, ownership, or nature of those funds or to promote further unlawful activity.

A monetary instrument that allows one person to make a payment to another person or entity for a specified amount. Money orders are commonly used for payments and remittances and may be subject to BSA recordkeeping and AML/CFT requirements.

A Money Services Business (MSB) is legal classification for a non-bank financial institution that facilitates the transmission, exchange, or conversion of money.

A person or business that, as a business, accepts currency, funds, or other value that substitutes for currency from one person and transmits it to another person or location by any means. Whether an activity constitutes money transmission is generally determined based on the facts and circumstances.

The process of obtaining and maintaining the licenses or registrations required by applicable state or other jurisdictions to legally conduct money transmission activities. Requirements vary by jurisdiction and may include applications, financial requirements, surety bonds, permissible investments, reporting, and ongoing examinations.

The process of reviewing customer activity, transactions, accounts, agents, or other activity to identify behavior that may indicate violations of law, policy, or regulatory requirements.

A system used by many U.S. states to administer money transmitter and other financial-services licenses.

Activity in which one financial institution or MSB accesses another institution's services indirectly through an intermediary or customer relationship. Nested relationships can make it more difficult to identify the parties ultimately conducting transactions and may increase AML/CFT risk.

An event or activity that does not directly involve the movement or exchange of money or monetary value but may still be relevant to compliance, such as changes to customer information, account status, ownership, or other customer profile information.

The process of screening customers, transactions, counterparties, and other relevant parties against sanctions lists administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) to identify potentially prohibited persons, entities, or transactions.

The Office of Foreign Assets Control (OFAC) administers and enforces U.S. economic and trade sanctions against targeted countries, organizations, and individuals, including terrorists, narcotics traffickers, and other threats to national security. These sanctions may be broad-based or targeted and often involve asset blocking, transaction prohibitions, and trade restrictions designed to support U.S. foreign policy and national security objectives.

The continuous or periodic review of customer relationships and transaction activity to identify changes in risk, unusual activity, or potential money laundering, terrorist financing, sanctions violations, or other financial crime.

The Payment Card Industry Data Security Standard (PCI DSS) is a set of security standards designed to protect cardholder data and reduce the risk of payment card fraud. It applies to organizations that store, process, or transmit credit card or debit card information and establishes requirements for securing payment systems, networks, and sensitive account data.

A business that facilitates the processing of payments between a payer and a merchant, biller, or other recipient. Whether a payment processor is considered a money transmitter depends on the nature of its activities and the facts and circumstances. FinCEN has recognized certain merchant payment processing activities as outside the money transmitter definition.

Assets or investments that a licensed money transmitter is legally permitted to hold to back outstanding payment obligations or customer funds. Specific permissible investments and requirements vary by state law.

Placement is the first stage of the traditional three-stage money laundering process. It involves introducing illicitly obtained funds into the legitimate financial system or converting them into financial instruments or assets.

An individual who is or has been entrusted with a prominent public function, as well as, depending on the applicable framework, certain family members and close associates. PEP status does not mean the person has engaged in wrongdoing, but it may indicate increased exposure to corruption or bribery risk.

A form of access to funds or monetary value that can be used by a person to obtain goods, services, or cash. Depending on the product and circumstances, prepaid access may be subject to BSA/AML requirements.

Principal MSB is the primary organization that directly holds the license, registration, and regulatory obligations. It is responsible for a network of authorized "agents" who process transactions on its behalf.

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) is Canada’s primary anti-money laundering and anti-terrorist financing law. It establishes the legal framework for detecting, deterring, and investigating money laundering and terrorist financing by requiring certain businesses and financial institutions to maintain records, verify client identity, monitor transactions, and report specified activities to FINTRAC, Canada’s financial intelligence unit.

A transaction that is prohibited by law, regulation, sanctions, contractual requirements, or an organization's internal policies. In an AML/CFT context, this may include transactions involving sanctioned parties or prohibited activities.

A risk-assessment methodology that evaluates risk using categories or professional judgment rather than relying exclusively on numerical scoring.

The process of creating, maintaining, and retaining required records concerning customers, transactions, compliance activities, and other information required by law or regulation.

A fact, pattern, behavior, transaction, or other indicator that may suggest money laundering, terrorist financing, fraud, sanctions evasion, or another form of illicit activity and warrants further review.

A person or business designated to receive legal and official documents on behalf of a company, such as service of process and certain government notices. A registered agent is distinct from an MSB agent unless the same business serves both roles.

The Restore Online Shoppers’ Confidence Act (ROSCA) is a federal law that protects consumers from deceptive online sales practices, particularly those involving negative option features such as automatic renewals, recurring charges, or trial offers that convert into paid subscriptions.

The Right to Financial Privacy Act (RFPA) is a federal law that protects the confidentiality of a customer’s financial records held by financial institutions. It establishes procedures that federal government agencies must follow before obtaining access to a customer’s financial information from a financial institution, generally requiring customer notice, consent, or legal process such as a subpoena, summons, or search warrant, unless an exception applies.

An Risk Assessment is the process an organization uses to identify, evaluate, and understand its exposure to money laundering, terrorist financing, and other financial crime risks. It helps the institution determine where its highest risks exist so it can apply appropriate controls, monitoring, and resources to manage those risks effectively and put the correct policies and procedures in place to develop the institutions AML/CFT program.

A compliance strategy that identifies and assesses an organization's financial crime risks and applies controls and resources proportionate to those risks. A risk-based approach recognizes that not all customers, products, services, transactions, or geographic areas present the same level of risk.

The written portion of a Suspicious Activity Report that explains the relevant suspicious activity. A strong SAR narrative clearly describes who was involved, what occurred, when and where it occurred, why the activity is suspicious, and how the activity was conducted.

The Servicemembers Civil Relief Act (SCRA) is a federal law that provides legal and financial protections to active-duty members of the U.S. military, helping them focus on their military responsibilities without certain civil obligations creating undue hardship. The SCRA provides protections related to areas such as interest rates on certain loans, rental and housing agreements, civil court proceedings, and other financial and contractual obligations.

A form of structuring in which an individual or group uses multiple people, accounts, or transactions to conduct financial activity in amounts designed to avoid detection or regulatory reporting requirements.

The origin of the specific money or assets involved in a transaction or customer relationship, such as salary, business revenue, sale of property, or another identifiable source.

The origin of a customer's overall wealth or assets, such as employment, business ownership, investments, inheritance, or other legitimate sources accumulated over time.

The practice of deliberately breaking transactions into smaller amounts or conducting transactions through multiple people or locations to evade a regulatory reporting or recordkeeping requirement. Structuring can itself be a federal offense.

A financial guarantee required by many state money transmission laws to protect customers and other parties if a licensed money transmitter fails to meet certain obligations.

The process of reviewing customer and transaction activity to identify patterns or behaviors that may indicate money laundering, terrorist financing, fraud, or other illicit activity and determining whether further investigation or reporting is required.

A Suspicious Activity Report (SAR) is a report that financial institutions must file when they detect transactions or activities that may involve money laundering, terrorist financing, fraud, tax evasion, or other criminal conduct. SARs help law enforcement and regulatory agencies identify, investigate, and prevent financial crimes.

In Canada, reporting entities are required to file Suspicious Transaction Reports (STRs) with FINTRAC as soon as practicable after determining that there are reasonable grounds to suspect a transaction or attempted transaction is connected to money laundering or terrorist financing. An STR may be triggered by unusual transaction patterns, inconsistent customer behavior, attempts to conceal the source of funds, or other indicators of suspicious activity.

The Telephone Consumer Protection Act (TCPA) is a federal law that regulates telemarketing calls, text messages, prerecorded or artificial voice calls, and the use of automated telephone dialing systems. The law is designed to protect consumers from unwanted and intrusive communications by requiring businesses to obtain appropriate consent before making certain types of calls or sending marketing text messages.

The provision, collection, movement, or use of funds or other assets with the knowledge or intent that they support terrorist acts, terrorists, or terrorist organizations. Unlike money laundering, terrorist financing may involve funds obtained from both legitimate and illegitimate sources.

The use of trade transactions to disguise, transfer, or legitimize proceeds of criminal activity, often through methods such as over- or under-invoicing, false documentation, or misrepresentation of goods and services.

The use of manual or automated processes to review transactions and identify activity that may be unusual, inconsistent with a customer's expected behavior, or indicative of money laundering, terrorist financing, fraud, or other financial crime.

A BSA requirement that certain financial institutions involved in transmittals of funds of $3,000 or more obtain, retain, and transmit specified information about the transmitter and recipient with the payment.

The Truth in Lending Act (TILA) is a federal law that promotes the informed use of consumer credit by requiring lenders to provide clear, accurate, and standardized disclosures about the terms and costs of credit. The law helps consumers compare credit products and make informed borrowing decisions.

The individual or individuals who ultimately own or control a legal entity. Identifying the UBO helps an organization understand who ultimately benefits from or controls a customer relationship.

Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) refers to conduct by financial institutions or service providers that harms consumers through unfair treatment, misleading representations, or abusive practices. UDAAP is prohibited under federal consumer financial protection laws and is enforced by the Consumer Financial Protection Bureau and other regulatory agencies.

The USA PATRIOT Act is a federal law passed shortly after the 9/11 terrorist attacks. Its main goal was to give law enforcement and intelligence agencies the necessary tools to detect, investigate, and prevent future terrorist attacks within the United States.

Customer or transaction activity that deviates from expected behavior or established patterns and may warrant further review. Unusual activity is not necessarily suspicious activity, but it may be an indicator that additional investigation is appropriate.

The process of confirming the accuracy and authenticity of information provided by a customer or other party using reliable documents, data, or other sources.

A digital representation of value that may function as a medium of exchange but does not necessarily have legal-tender status.

Comparing parties against sanctions, government, internal, or other risk-related lists.

A violation involving the level of intent or recklessness necessary to satisfy applicable statutory or regulatory standards, potentially resulting in significant civil or criminal consequences.

An electronic transfer of funds between financial institutions or parties.

A currency deposited or used outside the country or jurisdiction that issued it. For example, U.S. dollars held in a bank outside the United States may be considered a foreign-held or “xeno” currency.

Analytical approaches used to identify changes or anomalies in customer or agent activity over time.

System activity that may not itself transfer funds, but can still provide relevant information for fraud, AML, or account-monitoring investigations.

An internal compliance term describing activity prohibited by an institution's policies regardless of transaction value or customer risk rating.