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

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Table of Contents Financial Crimes Enforcement Network Executive Summary 1 Introduction 3 Background on BSA and AML Programs 5 Business Volume/ Scope 8 AML Program Overview 9 Risk Assessment 11 Independent Review 14 Retail Oversight 15 Agent Oversight 16 Mystery Shopper Visits 18 Customer Identification 19 Transaction and Activity Monitoring 20 Automated Alerts 20 Front-Line Referrals 21 Filing BSA <strong>Report</strong>s 22 Investigations/SAR Filings Determinations 23 Account Closure Policies 24 Training 25 Financial Intelligence Unit (FIU) 28 Law Enforcement Partnership 29 Additional Observations 30 MSB BSA/AML Examination Manual and Examination Issues 30 314(b) Voluntary Information Sharing 32 Maintaining Banking Services 33 FinCEN Materials 33 Additional Guidance Requested 34 Prepaid Access 34 SAR Sharing 35 Virtual Currency Operators 35 <strong>Report</strong> on Outreach to Money Services Businesses ii
Financial Crimes Enforcement Network Conclusion 36 Appendix I: Resources Available to MSBs 37 Appendix II: Acronym List 40 <strong>Report</strong> on Outreach to Money Services Businesses iii
Page 1: Financial Crimes Enforcement Networ
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Page 8 and 9: Introduction Financial Crimes Enfor
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Page 16 and 17: Risk Assessment Financial Crimes En
Page 20 and 21: Retail Oversight Financial Crimes E
Page 30 and 31: Training Financial Crimes Enforceme
Page 38 and 39: Maintaining Banking Services Financ
Page 40 and 41: SAR Sharing Financial Crimes Enforc
Page 42 and 43: Appendix I Resources Available to M
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1 Report on Outreach to Money Services Businesses ... - FinCEN

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