In reference to the FinCEN ruling 2005-3:

"A business that develops, implements, and abides by, written policies and procedures that provide that it will no longer cash checks in amounts sufficient to reach the $1,000 definitional threshold for a check casher would cease to be a check casher for purpose of the Bank Secrecy Act..."

Has anyone developed a policy with procedures for a customer? We are looking to do this, but not sure how detailed it has to be, or where to start!

All help is appreciated!

I'm probably reading your post incorrectly. Did you state that you are developing a policy and/or procedure for your customer?

Yes, it is for a customer. They aren't sure where to start and asked us for help.

I'm slapping ACB on the back, trying to get his heart beating and some air back into his lungs... When the color returns to his face he will probably say that this is a really, really bad idea.

There is a BSA/AML Examination Manual for MSB's. You should refer them to it and stop right there.

No bank should act a consultant to a customer, particularly an MSB. My apologies, but they should at least know what their procedures are; all they have to do is write down what they do.

I'll just toss in a guess here that the OP's customer is probably a small "mom & pop" store who inadvertently cashed checks without realizing that they crossed into the MSB Zone and have no idea how to find their way out. IMPE (in my past experiences) these folks typically do not use English as their primary language thus making the lines of communication even more confusing.

Rachelchri, I just got thru working with an MSB customer and I did exactly what Ken said my customers do not use English as their primary language, but they got it done. They got someone to help them call and find out what they needed and sent me a copy. They also had to provide a copy to register as an MSB and they were only given a certain amount of days to get that done.

FinCEN has documents in both English and Spanish.
Direct them to the site, or print out the spanish version for them.

Thanks Ken. Death by AML would have been an embarrassing way to go.

I agree by 100%. You're a bank, not consultant. Ken's advice is sound. Point them to the MSB Manual and be done with it.