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In Response To:
Thread Starter: ColoradoAML
Title: Re: used car dealer is an NBFI???

I think it's entirely appropriate if you don't consider all NBFIs to have the same amount of risk and to treat them differently. A used card dealer - especially one that finances loans - can certainly be used to launder money. It seems totally likely to me that if they had a repeat customer who frequently bought and financed cars, and paid monthly in cash, many dealership would be very happy to have that customer and not ask questions. When that money eventually finds its way into your institution, it may become your problem, especially if you haven't addressed the risk at all in your BSA program. Just like with all NBFIs, you don't necessarily know who your customers' customers are. Again, it's my opinion that the customer you described poses AML risk as a "loan or finance company."

And while you may choose not to monitor car dealerships with the same scrutiny that you monitor MSBs, by definition they are NBFIs.