1 Report on Outreach to Money Services Businesses ... - FinCEN

Financial Crimes Enforcement Network
Another MSB also stressed that compliance is everybody’s responsibility. It views the
following as the four “cornerstones” of the compliance program:
•
•
•
•
Agent on-boarding;
A dedicated compliance team;
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Agent supervision and transaction monitoring; and
Training.
One MSB emphasized its global approach to AML compliance and detection. The
MSB deters and detects money laundering and fraud through its internal policies,
which include controls that are used to keep its system free from “high risk users”
and transactions. Proprietary in-house programs and highly trained staff review
accounts and transactions and internal as well as external resources are utilized to
recover losses from fraudulent activity.
One MSB has implemented a policy, in addition to a manual exception policy, that
prohibits individual transactions from exceeding $10,000. Once the total volume
of transactions reaches $2,000, it requires either a Social Security number or the
account holder must link the account to another financial institution, such as a bank
or credit card.
25. Agent on-boarding is generally described as the initial process in which an MSB principal educates
and trains the new agent on expectations as to their roles and responsibilities as an agent for the MSB
principal
<strong>Report</strong> on Outreach to Money Services Businesses
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