This isn't a new concept. FinCEN inttroduced the requirement to subject indirect monetary instrument sales to recordkeeping requirements in November 2002. The verbiage of the Exam Manual may have gotten a facelift, but the guidance below has bee around for almost two decades.
https://www.fincen.gov/resources/st...erpreting-financial-institution-policiesFrom an automated system perspective, see if you can prepare a query or report that identifies accounts that have monetary instrument purchases and cash deposits on the same business day. If this is not an option, make sure you are training tellers to identify monetary instrument purchases that are preceded by cash deposits.
To satisfy the recordkeeping requirement, you have to make sure that you have Name, address, tax ID, and birthdate for the purchaser along with the specifics of the monetary instrument. Whether you have a log for this or retain the information on a system report is up to you.
For suspicious activity montioring, if your automated solution does not generate alerts for monetary instrument pruchases, then you should have a manual process for reviewing individuals who make frequent purchases or multiple individuals who all make purchases payable to the same third party to identify suspicious activity trends, placement, funnelling, layering, etc.
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