Regulatory Alerts2004-12-14
Added
Interpretive Release 2004-1: Anti-Money Laundering Program Requirements for Money Services Businesses With Respect to Foreign Agents or Foreign Counterparties
This interpretive release clarifies that Money Services Businesses required to register with FinCEN must establish and maintain anti-money laundering programs that include adequate and appropriate policies, procedures, and controls commensurate with the risks posed by their relationships with foreign agents or foreign counterparties. The guidance requires these businesses to conduct risk-based due diligence on such foreign entities and implement risk-based monitoring of transactions flowing through them to detect money laundering or terrorist financing. This obligation applies specifically to Money Services Businesses, including currency dealers, check cashers, issuers of traveler’s checks, money orders, or stored value, sellers or redeemers of such instruments, and money transmitters.