Regulatory Alerts2016-03-11
Guidance on Existing AML Program Rule Compliance Obligations for MSB Principals with Respect to Agent Monitoring
The Financial Crimes Enforcement Network (FinCEN) issued this guidance to reiterate the anti-money laundering program obligations of money services business (MSB) principals regarding the monitoring of their agents. The document requires principals to implement risk-based policies and procedures to identify agent owners, evaluate ongoing operations, and ensure adequate controls to mitigate money laundering and terrorist financing risks. It emphasizes that principals and agents remain independently liable for compliance and must tailor their programs to specific business risks while maintaining a strong culture of compliance.
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