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News Releases
12/09/2004 USA PATRIOT Act Monitor News Release: Interpretive
Guidance for AML Programs of MSBs
FinCEN has posted interpretive guidance for money services businesses (soon
to appear in the Federal Register), specifying AML program requirements for
MSBs that use foreign agents and counterparties. Although the guidance reviews
31 CFR 103.125 (AML programs for MSBs), there are specifics in the guidance
that should receive careful attention from covered institutions. The guidance
notes that an MSB using foreign agents should have procedures for identifying
material changes in an agent's risk profile, such as a change in ownership,
business, or the regulatory scrutiny to which it is subject. A breakdown in
a foreign agent's implementation of an effective anti-money laundering program
should be detectable where "obvious." Transactional reviews should
be able to identify suspicious activities involving wire activity, bulk sales
or purchases of sequentially numbered instruments, multiple purchases or sales
that appear to be structured, and illegible or missing customer information.
The Interpretive Guidance will be discussed in detail in the January issue of
the Monitor, and will be included in the forthcoming revision of Part II of
Money Laundering, Terrorism and Financial Institutions.
USA PATRIOT ACT MONITOR is published by Civic Research Institute, Inc., 4478 U.S. Route 27, P.O. Box 585, Kingston, NJ 08528, 609-683-4450, info@civicresearchinstitute.com, as an update service for Money Laundering, Terrorism and Financial Institutions: Law · Regulation · Compliance · USA PATRIOT Act Monitor © 2004 Civic Research Institute, Inc. All rights reserved. Unauthorized copying expressly prohibited. The information in this publication is not intended to replace the services of a trained legal professional. Neither the editors, nor the contributors, nor Civic Research Institute, Inc. are by this publication engaged in rendering legal, accounting, or other professional services. The editors, contributors, and Civic Research Institute, Inc., specifically disclaim any liability, loss, or risk, personal or otherwise, which is incurred as a consequence, directly or indirectly, of the use or application of the contents of this publication.