Skip to content
BOL Conferences
Thread Options
#1583550 - 07/27/11 12:41 PM MSB Registration
n2compliance Offline
100 Club
n2compliance
Joined: May 2011
Posts: 102
If we verify on the FinCEN website that our MSBs are registered....is that enough? Or are we required to also get a copy of their registration? If a copy of required, can someone show me where that is stated, because I KNOW I will have to prove it to my customers and managers! Thank you!!

Return to Top
BSA/AML/CIP/OFAC Forum
#1583566 - 07/27/11 01:26 PM Re: MSB Registration n2compliance
bhazzard Offline
100 Club
Joined: Dec 2010
Posts: 120
It may not be much help but we also just verify the registration list. If the customer is a high rish MSB we request their AML documents such as their policy, rules for operation, training procedures and training logs etc.

Return to Top
#1583601 - 07/27/11 01:51 PM Re: MSB Registration bhazzard
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
It is clearly stated on the FinCEN Web site "The List is intended only as general reference for the public and should not be treated as determinative of an entity’s registration status". For that reason we have always required copies of FinCEN's acknowledgement of their registration.

Return to Top
#1583636 - 07/27/11 02:26 PM Re: MSB Registration n2compliance
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I just want to add and emphasize the sentence following Devsfan's quote:

The List is intended only as general reference for the public and should not be treated as determinative of an entity’s registration status. The only determinative evidence of an entity’s registration status is the acknowledgement letter from IRS-ECC-D that an entity receives after filing its registration.

Found here. I'm not certain what the purpose of the MSB list is, but it is not to verify registration.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1583747 - 07/27/11 03:28 PM Re: MSB Registration Elwood P. Dowd
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,365
Galveston, TX
Plus, the FinCEN list that is provided only reports the last form filed by the MSB. You have no idea if it was a renewal, amendment, etc. I would highly recommend that get a copy of the IRS confirmation from the customer.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1584100 - 07/27/11 08:24 PM Re: MSB Registration rlcarey
Bobw Offline
Gold Star
Bobw
Joined: Nov 2006
Posts: 336
New England
Totally agree, we had a MSB that tried to play that game and I would not budge until I have a copy of the IRS form. This guy wires money international
_________________________
just my opinion, based on my 30+ years

GO RED SOX!!!

Return to Top
#1584815 - 07/28/11 07:39 PM Re: MSB Registration Bobw
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 346
Mid-Atlantic
The FFIEC Exam Manual does have the due diligence that the bank should conduct (and documents to request) when it provides banking services to MSB's. Check out pages 307 to 315 of the manual for what you should be obtaining from the MSB.
_________________________
CAMS
CAFP

Return to Top

Moderator:  Andy_Z