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New Milenium Cash Exchange, Inc. and Flor Angella Lopez

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FinCEN has assessed a civil money penalty of $10,000 against New Milenium Cash Exchange, Inc. (NMCE) and its owner, Flor Angella Lopez, for multiple violations of BSA/AML regulations. FinCEN found that NMCE operated as a "financial institution" and "money services business" as those terms are defined in 31 CFR §§ 1010.100(t) and (ff). Since 2006, three IRS exams of NMCE identified repeated violations of the BSA. The Florida Office of Financial Regulation also examined NMCE and found violations resulting in a written corrective action agreement and a fine in 2011. FinCEN determined that MNCE and Lopez willfully violated the BSA's program, reporting and recordkeeping requirements since at least 2008. NMCE and/or Lopez:

  • conducted business without continuous FinCEN registration for over three years
  • submitted MSB registrations in 2011 containing inaccurate information on services rendered by NMCE
  • failed to establish and implement an effective written anti-money laundering program
  • lacked adequate AML programs for check cashing and money order activities and currency exchange transactions
  • failed to have policies, procedures and internal controls to adequately verify the identity of persons conducting transactionsl to monitor for suspicious
  • activity, to identify reportable currency transactions, or ensure the filing of CTRs
  • failed to make or retain adequate records
  • lacked a BSA/AML risk assessment
  • provided no or inadequate training
  • filed 51 CTRs covering transactions totaling about one million dollars significantly late
  • failed to file at least 149 CTRs for exchanges of currency with other financial institutions.

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