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12
ANTI-MONEY LAUNDERING (AML) PROGRAM
of
Every MSB is required by law to have an effective Anti-Money
Laundering (AML) Program. This program must:
Bank Secrecy Act &
Anti-Money Laundering
(BSA/AML)
TRUSTEE TRAINING

Designate a Compliance Officer
o
Responsible for total oversight of the AML program

Incorporate written policies, procedures, and internal controls to
assure compliance with BSA

Provide education and/or training to appropriate employees
o

Maintain records of when, what and which new and existing
employees trained
Independent review of AML Program
o To be completed by someone other than the designated
Compliance officer for the purpose of monitoring the
adequacy of the AML program. The review should include
but not limited to a review of policies, transactions, reporting
completeness and accuracy, and assurance of employee
AML training.
BANK SECRECY ACT (BSA)
The Bank Secrecy Act (BSA) is intended to help federal authorities in
the investigation of money laundering and terrorist financing by
requiring money service businesses (MSBs) to comply with certain:

Reporting and recordkeeping requirements;

Procedures in verification of customer identity; and

Collection of customer information
Global Express offers 2 types of MSB services: money orders and
money transmission. Certain bill payment and prepaid products are
considered money transmission under the BSA. As an MSB, each
Trustee of Global Express must comply with BSA anti-money
laundering (AML) program and reporting and record keeping
requirements.
BSA REPORTING AND RECORD KEEPING
REQUIREMENTS
MONETARY INSTRUMENT LOG
If cash is used to purchase one or more money orders and/or bill
payments totaling at least $3,000 but not more than $10,000
(inclusive of fees) in one or related transactions, the Trustee must
obtain and record specific information, including identifying
information from the customer(s). Process includes:
1)
Obtain, verify and record customer information, including
identification
Acceptable identification:
o
o
The BSA requires certain MSBs to register with FinCEN. As a
Trustee of Global Express, you are not required to file your own
registration unless you offer your customers other financial products
or services independent of Global Express.
2)
For more information regarding legal obligations on how BSA
regulations apply to your business visit: www.fincen.gov.
o
U.S. alien registration
o
Other government issued identification with photo
Record customer and transaction information
o
o
Name and address of the purchaser*
Number from ID*
o
o
Date of Birth of purchaser*
Date of purchase
o
o
3)
For additional compliance resources as a Trustee of
Global Express, please visit
http://global.tionetworks.com/compliance/
Driver’s license
Passport
Location of purchase
Type of instrument, serial numbers and total number
of instruments purchased
o
Dollar amount purchased and the amount of each
instrument
o
If the purchaser is buying the instruments on behalf
of another person, the (*) information is also
required for that person
Retain Log for five (5) years
22
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BSA/AML
TRUSTEE TRAINING CONTINUED
BSA REPORTING AND RECORD KEEPING
REQUIREMENTS CONT.
CURRENCY TRANSACTION REPORTS (CTR)MSBs must report all
cash transactions that exceed $10,000 using a Currency Transaction
Report (CTR) when a transaction or series of related transaction(s)
meet all of the following conditions:

The transaction(s) is made in cash;

The transaction(s) is greater than $10,000;

The transaction(s) is made by, or on behalf of, the same person;

The transaction(s) is conducted on the same day
FILING THE CTR
It is the responsibility of the Trustee to complete the CTR form found
on the BSA E-Filing section at FinCEN’ s website within 15 days
following the day of the transaction. CTRs must be maintained by
the filing MSB for five (5) years.
SUSPICIOUS ACTIVITY REPORTS (SAR)
These reports are used by the government to fight against money
laundering and other money services crimes. A SAR report must be
filed whenever a transaction or a series of transactions is both:
1)
At least $2,000; and
2)
Deemed by the Trustee to be suspicious.
STRUCTURING
When a customer intentionally splits a transaction into two or more
separate transactions in order to avoid providing identifying
information is called “structuring”. Structuring is intended to evade
the BSA reporting and recordkeeping requirements (for example:
$3,000 or $10,000) and is a criminal and civil violation. This activity,
if deemed to be suspicious, must be filed under a SAR.
Red flags of potential suspicious activity:

Several purchasers come in together but pretend not to know
each other and conduct similar transactions;

The customer provides inconsistent answers to questions

The same customer buys money orders more than once in a day
or in two or three consecutive days

The customer offers you a bribe to no require identifying
information

The customer are just below the $3,000 record keeping threshold

The customer asks whether the purchase will be
recorded/reported

The customer alters the transaction upon learning ID is required
To help determine if a transaction seems suspicious, questions to
ask one-self could be:

Is the transaction amount unusually large for the typical
customer?

Does the customer make the same or similar transactions more
frequently than normal?

Does the type of transaction seem unusual for the customer?
FILING THE SAR
It is the responsibility of the Trustee to complete a SAR form found
on the BSA E-Filing section at FinCEN’s website within 30 days after
the Trustee discovers the suspicious nature of the activity.
Trustee should include all relevant information regarding the
transaction(s) and person(s) involved in the transaction(s) and should
clearly state why the activity appears suspicious.
A copy of each SAR filed must be kept for a period of five (5) years
from the date of the filing of SAR. Be prepared to provide copies of
SARs to any state examiners and/or IRS examiners.
DO NOT DISCLOSE. Never disclose to a customer the fact a SAR
has been filed.
A transaction is suspicious and must be reported if the Trustee
knows, suspects or has reason to suspect that the transaction(s):

Involves funds from illegal activity

Is intended or conducted in order to hide or disguise funds or
assets derived from illegal activity

Is designed to evade reporting or record-keeping requirements;
or

Serves no business or apparent lawful purpose
QUESTIONS?
If you have questions about how these laws apply to your
business, consult your own legal advisor.
If you have any questions about the contents of this
training guide, please contact us @
[email protected]