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#1478971 - 12/10/10 03:30 PM MSB with lapsed registration
LFTbanker Offline
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Joined: Dec 2008
Posts: 137
I don't recall seeing this come up in the past, and I just wanted to verify my thinking. If we detect an MSB that has not registered with FinCEN, we file a SAR on them and require that they get registered, stop the activity (usually cashing checks) or close the account. If we find that an MSB has let their registration lapse, no question that we make them re-register, but would anyone think that we should then file on them? My thinking is not unless it appeared that this was caused by more than an oversight, but I wanted to get other opinions. Thanks for any thoughts.

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#1479272 - 12/10/10 08:41 PM Re: MSB with lapsed registration LFTbanker
What?? Offline
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Joined: Feb 2007
Posts: 170
It would depend. If the MSB forgot and filed right away, I wouldn't file a SAR. We have a process where we notify all of the branches when the MSB will expire (prior to the expiration date) and we obtain a copy of the MSB application in file so we know it's in the process and we follow up by the next analysis review.

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#1479283 - 12/10/10 08:50 PM Re: MSB with lapsed registration What??
Dallas Fan Offline
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Joined: Feb 2008
Posts: 219
Agreed, it could very well be an honest mistake and if they are going to refile then it's just a waste of time for you and the Fed if you file a SAR.

Talk to your customer. If they don't want to update their registration ASAP then you would simply close the account and file a SAR.

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#1479303 - 12/10/10 09:03 PM Re: MSB with lapsed registration What??
nemsi Offline
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Joined: Nov 2005
Posts: 383
I agree with SAR Queen.

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#1479358 - 12/10/10 09:52 PM Re: MSB with lapsed registration nemsi
ahou Offline
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Joined: Aug 2002
Posts: 3,094
We've never had to do this. Is there a dollar threshold? What box in part III would be checked for type of suspicious activity?
Opinions are my own and not of my employer.

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#1479433 - 12/11/10 02:10 AM Re: MSB with lapsed registration ahou
rlcarey Online
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Joined: Jul 2001
Posts: 82,469
Galveston, TX
An unregistered MSB is a violation of Federal law. How could you not file a SAR, regardless of the circumstances??
The opinions expressed here should not be construed to be those of my employer:

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