Question: What is required of Money Service Businesses (MSBs) according to the Bank Secrecy Act (BSA) and how can MSBs ensure that they are in compliance with the Act?
Answer:
The Financial Crimes Enforcement Network (FinCEN) recently issued a notice designed to clarify which entities qualify as Money Services Businesses (MSBs) by describing the types of financial activity that will subject a business to the Bank Secrecy Act (BSA) implementing rules.
The BSA requires that all MSBs:
Register and provide agent lists.
Report suspicious activity.
Report large currency transactions.
Report large purchases of monetary instruments.
Report currency exchanges.
Report large wire transfers.
Share information.
Implement an Anti Money Laundering (AML) program.
Implement a Customer Identification Program (CIP).
Comply with all Office of Foreign Assets Control (OFAC) restrictions.
In order to ensure compliance with the BSA, MSBs should provide their employees with up-to-date training on how to execute their job responsibilities in accordance to the BSA.
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