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#2075496 - 04/25/16 05:02 PM Crowdfunding - BSA Risks
Madawaska Offline
100 Club
Joined: Sep 2008
Posts: 105
VA
I am looking for some good information regarding Crowdfunding businesses and the BSA risks associated with having this type of customer relationship and activity in the Bank. This would be for investment crowdfunding; not charitable crowdfunding. Investors would pay (via ACH debit) only after monies have been raised for a particular investment that they are interested in investing.

Also, what NAICS code would apply to a Crowdfunding business? I understand they are regulated by the SEC.

Thanks!

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#2075497 - 04/25/16 05:05 PM Re: Crowdfunding - BSA Risks Madawaska
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
What has been described to you as "crowd funding" sounds like a "private investment company" to me. In other words, you will have one account with money belonging to a number of different, unidentified people. The Examination Manual notes that these types of companies can be used for money laundering and terrorist financing.

My apologies, if I misunderstand the mechanics...
Last edited by Ken_Pegasus; 04/26/16 12:03 PM.
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