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#1309397 - 12/18/09 05:55 PM Banking Walmart
BSAKeeper Offline
Junior Member
Joined: Aug 2007
Posts: 44
TN
Since Walmart sells Money Orders and Gift Cards and is a Money Transmitter and Check Casher, would they qualify for a Phase I Exemption? If so, what documentation would you request during their annual review?

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#1309400 - 12/18/09 05:58 PM Re: Banking Walmart BSAKeeper
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
What annual review other than making sure they were still a listed company?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1309504 - 12/18/09 07:05 PM Re: Banking Walmart rlcarey
BSAKeeper Offline
Junior Member
Joined: Aug 2007
Posts: 44
TN
Maybe I am confused, but according to my understanding the only time an annual review is not required for a Phase I Exemption is for a Bank or Government Entity. Are you saying we only need to verify that they are still publicly traded?

Since they now cash checks, sell money orders,and are a money transmitter would they even qualify to be exempt?

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#1309523 - 12/18/09 07:32 PM Re: Banking Walmart BSAKeeper
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
There is no limitation on publicly traded companies. For review guidance see the top of page 82 in the BSA/AML Exam Manual.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1310271 - 12/21/09 05:33 PM Re: Banking Walmart BSAKeeper
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
Originally Posted By: ccl

Since they now cash checks, sell money orders,and are a money transmitter would they even qualify to be exempt?


Everytime I say "Walmart", I like to add "5th largest MSB in the US."

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