MSB bank account closures are avoidable. These are the most common reasons why a bank will close down an MSB account. COMMON REASONS FOR MSB BANK CLOSURES Outdated BSA/AML/OFAC Compliance Program Deficient Independent Review Insufficient Recordkeeping Improper CRT/SAR Filing Outdated BSA/AML/OFAC Compliance Program The BSA/AML/OFAC Compliance Program must be risk-based, satisfy the five anti-money laundering […]
The Financial Crimes Enforcement Network (FinCEN) has released an advisory concerning Unemployment Insurance (UI) fraud related to the COVID-19 pandemic. Money Services Businesses (MSBs) must be aware of different types of potential fraud, red flags to look for and how to file a Suspicious Activity Report (SAR) accordingly. FRAUD During the COVID-19 pandemic, UI claims […]
An Anti Money Laundering (AML) Program is a set of policies, procedures and internal controls designed to prevent money laundering and terrorist financing. If you are a business that provides money services, you will need an AML Program to satisfy regulators, avoid costly fines and prevent criminal punishment. MONEY SERVICES BUSINESS An organization that provides […]
FinCEN released a series of advisories about financial crimes related to the COVID-19 pandemic. Money services businesses (MSBs) are especially vulnerable to financial crime during this uncertain time. The purpose of the series of advisories is to reinforce that: “Detecting, preventing, and reporting COVID-19 related scams and illicit activity is critical to our national security, […]
Financial Crimes Enforcement Network (FinCEN) released a notice on May 18, 2020 in response to reporting requirements as they relate to COVID-19. The COVID-19 pandemic has left many of us vulnerable. It is important now more than ever to report suspicious activity to combat financial crimes. BSA REPORTING OBLIGATIONS FinCEN expects financial institutions to adhere to […]
