BSA Data Assists Oklahoma in MSB Licensing
By Dudley Gilbert, Oklahoma State Banking Department
The Oklahoma State Banking Department began licensing money transmitters in 2007 in cooperation with the Oklahoma State Bureau of Narcotics and Dangerous Drugs Control (?OBN?). Oklahoma law requires the OBN to conduct a ?criminal financial check? on all applicants for a money transmitter license, and requires the applicant to pay a separate fee to OBN for such background reviews. As part of the licensing process, information is collected on all directors and managing officers of an applicant and is used by the OBN to review not only an individual?s criminal record but also information that may have been recorded in SARs filed with FinCEN.
Upon completion of the background review, OBN sends a report to the Banking Department listing criminal convictions as well as the number of SARs that may have been filed with respect to the applicant?s managers and directors. The Banking Department may conduct further investigations on the individual, including contacting FinCEN to obtain copies of the actual SARs that have been filed. The Banking Department does not take any adverse action based solely upon the suspicions expressed in a SAR, but uses this information to investigate and reach an independent judgment about license applicants.
In addition to the background review at the time of application, any new managing officer and director must complete a form authorizing a financial background review as part of the annual license renewal process. These reviews give the Banking Department information that it may use when determining whether a licensee?s managers and directors have the competence, experience, character, and general fitness to permit the applicant to engage in money transmission in Oklahoma.
Excerpted from SAR Activity Review Issue 14, page 11
First published on 10/01/2008