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#646431 - 12/04/06 04:52 PM MSB BSA/AML Policy
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
We have a registered MSB that we do business with. They have 2 BSA Officers, but when we asked them for a copy of their BSA/AML policy they stated that they do not have one. Aren't they required to have one? Now what do I do?!?!?
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BSA/AML/CIP/OFAC Forum
#646736 - 12/04/06 09:43 PM Re: MSB BSA/AML Policy J2C
Compliancer Offline
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Compliancer
Joined: Jan 2006
Posts: 334
San Francisco, CA
They might or might not depending on the scope of business that they perform. Go here

http://www.occ.treas.gov/BSA/pages_manual/OLM_104.htm

There is the "operator of a credit card system" provision and the "licensed sender of money...." provision which might pertain to them.

Now since you do business with them, just tell them that if they want to keep doing business with you, then they better get a policy. Even if you don't have the power to make that decision, they don't know that.
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