Question: We have a depositor who sells traveler's checks for Travel X.
What type of letter do you send to a MSB that is not registered? Does anyone have any suggestions?
Are MSBs required to register with FinCEN for accepting utility payments and making payday loans?
What information should we be obtaining from our existing MSB accounts concerning their policies and procedures, and how are we to know if they are in fact following their own procedures...and does it matter?
In the answer given by Ryan Rasske on "AML Requirements Upon Identifying an MSB", he stated, "It is up to the bank to conduct the proper due diligence on their MSB customers and ensure they are complying with the law." We are in the process of determining what our responsibility is as a bank to ensure that our customers are complying with the law. What specifically do we need to be doing to be sure that we are using "proper due diligence"?
Could you expand upon the implications of having cash-intensive retailers (i.e. grocery stores) who are registered with FinCEN as MSBs? It just came to our attention that because they're an MSB they cannot be exempted, nor can we exempt the grocery store portion of their business and continue to file on the MSB portion unless they're operated under separate TINs. If that's the case, a bank would often need to file a daily CTR, further clogging FinCEN's database. This seems like a regulatory policy that's contrary to the intention of the CTR process. Do we really want 260 more CTRs in the system for a legitimate business? Shouldn't the fact that they've registered with FinCEN make them legitimate and exemptable? Am I missing something? What solutions do you see to such a situation? I suspect many banks are struggling with this emerging issue and would welcome your guidance.
I work for a convience store which is registered as a MSB. Our banker told us we would need to write a policies and procedures. Could you help with a sample or example. Or would you know where I might find one? We currently cash checks and sell money orders.
I'm confused about our bank's obligations regarding money service businesses. Specifically, we have a customer who is an agent for an MSB. We're concerned, because he is accepting cash from his customers, depositing it with us, then wiring the funds by means of RIO (a western-union type company), so that RIO can prepare a draft on behalf of the beneficiary. Should we be asking our customer to do a CIP?
Depository Institution SARs (Treasury Form TD F 90-22.47) filed in paper format should be mailed to:
FAQs from FinCEN Help Line ? 314a Process