Regulatory Alerts2005-04-26
Added
Interagency Interpretive Guidance on Providing Banking Services to Money Services Businesses Operating in the United States
This interpretive guidance clarifies Bank Secrecy Act requirements for banking organizations providing services to money services businesses (MSBs) in the United States. It sets minimum due diligence steps, including applying Customer Identification Programs, confirming FinCEN registration and state licensing where applicable, confirming agent status, and conducting a basic Bank Secrecy Act/Anti-Money Laundering risk assessment. Banking organizations are expected to apply requirements on a risk-assessed basis, not holding them responsible for their customers' compliance, and must file a suspicious activity report if an MSB customer is found operating in violation of registration or state licensing requirements. The guidance will be reflected in forthcoming interagency Bank Secrecy Act/Anti-Money Laundering examination procedures.