aml compliance

Reporting and Record-Keeping Requirements

Agents must report suspicious activity by a customer or by an employee to the federal government on a form called the Suspicious Activity Report by Money Services Business (SAR-MSB).

Suspicious Activity Reporting (SAR)
by Money Services Businesses (MSB)

You must file a SAR-MSB report whenever one or more transactions that add up to $2,000 or more are conducted or attempted at your location and the transaction is suspicious in some manner.

Currency Transaction Report

Agents must file a Currency Transaction Report (CTR), for a cash sale of money orders or a money transfer to, or on behalf of the same person, which involves a transaction in currency of more than $10,000 during any one-business day (calendar day). This form must be sent to the IRS within 15 calendar days and a copy must be kept at your business or your home office location for five years.

Record Keeping of Transactions

Agents are required to make a record of all transactions between $3,000 and $10,000 using the High Dollar Transaction Report or a similar form. Agents must mail or fax a copy of the High Dollar Transaction form to MEMO's compliance department. Agents must keep the High Dollar Transaction Report at their business or their home office for five years.



 

More Information

Refer to www.msb.gov for more information from the federal government.



Downloads

For more information on the Currency Transaction Report, the Suspicious Activity Report and the recordkeeping of transactions, visit the Federal Crimes Enforcement Network (FinCEN) web site for money services business at www.MSB.gov.


Intentional failure to file a SAR-MSB can constitute a criminal act. SAR-MSB forms must be filed within 30 days of the transaction or attempted transaction and a copy kept at the agent's business or their home office location for five years. Suspicious activity includes, among other things, the following:

Involves money obtained from some sort of illegal activity.
Has no business or apparent lawful purpose and you know of no reasonable explanation for the transaction.
The customer is attempting to keep the transaction from being reported by buying money orders in amounts that would not require them to provide information about the transaction.
The customer is providing false or expired identification.
One or more individuals split up a single transaction so they do not have to provide information about the transaction.

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