STORE NAME:

Anti-Money
Laundering
Compliance Program
Compliance Officer:

Fax:
E-mail:

Updated: ________________________
 Table of Contents

Chapter 1
Adoption of a Compliance Program
Designation of a Compliance Officer
Employee Training
Independent Review

Chapter 2
Money Laundering Overview
MSB Registration
USA Patriot Act
Office of Foreign Control (OFAC)
Customer Awareness
Employee Awareness

Chapter 3
Recordkeeping
Currency Transaction Reporting
Structuring
Suspicious Activity Reporting

Chapter 4
Independent Review of Anti-Money Laundering Program
Financial Crimes Enforcement Network
Office of Foreign Control (OFAC)
Terrorism Financing Prevention

Chapter 5
Agent Outline

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 Chapter 1

Adoption of Compliance Plan

The purpose of our AML compliance plan is to establish the general framework for the fight
against money laundering, terrorism, corruption and other financial crimes.
(Store name)___________________________________ is committed to reviewing our AML
strategies and objectives on an ongoing basis and to maintaining an effective AML program. We
are committed to high standards of AML compliance and require management, employees, and
agents to adhere to these standards in preventing the use of our products and services for
money laundering purposes.
Adherence to this policy is absolutely fundamental for ensuring that all of our entities, regardless
of geographic location, comply with applicable anti money laundering legislation. We are
required and committed to adhere to minimum standards of anti money laundering compliance
based on the applicable anti-money laundering laws and regulations and any additional
standards from our regulatory supervisors which clarify the main statutory duties imposed on
our institution.
Our AML program is formulated and directed by the anti-money laundering department, but it is
the responsibility of all employees and agents to keep our products and services from being
used illegally to aid in money laundering or terrorist financing.

(Store name)____________________________________ has adopted this anti-money laundering

compliance plan in response to requirements set forth by the USA Patriot Act of 2001.

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 Designation of Compliance Officer

(Store Name)____________________________________ agrees to formally designate a competent

individual to serve as its Compliance Officer. The designated employee should be in a position of
responsibility that allows them to implement an effective Anti-Money Laundering Compliance Program.

The Compliance Officer, along with senior management, is responsible for ensuring the ongoing
compliance of this MSB with all federal and state anti-money laundering laws and regulations.

The Compliance Officers duties will include: ensuring proper compliance training of all staff involved in
MSB activities, proper record keeping and reporting as mandated by the Bank Secrecy Act, updating the
compliance program as necessary due to changes in laws or regulations, maintaining compliance with
licensing laws and OFAC requirements, and ensuring adherence to any related compliance laws or
legislation.

The Compliance Officer is also responsible for ensuring that a periodic review is conducted on the quality
of the Compliance Program. This review may not be conducted by the Compliance Officer. The review
should be done by a senior level employee or qualified professional who understands the requirements of
an effective compliance plan.

Designation of Anti-Money Laundering Compliance Officer

(Compliance office name)__________________________________________ is hereby designated as the

Anti-Money Laundering Compliance Officer for (Store name) __________________________________.
The Compliance Officer, as well as senior management, is responsible for ensuring the ongoing
compliance of this entity with all state and federal anti-money laundering laws, and for insuring all
employees are trained on anti-money laundering requirements before conducting any Money Service
Business activity.

Date: ____________________________________

Name: ___________________________________

Title: _____________________________________

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 Employee Training

A key component of an effective compliance program is employee training. Minimum training must
include, how to identify suspicious activity and structured transactions, recordkeeping, recording, and
reporting requirements, verifying identification, and familiarity with anti-money laundering forms.

All employees should be required to read this manual and sign a copy of the Acknowledgement of
Employee Training that will be retained in their personnel file or Anti-Money laundering files.

Acknowledgement of Employee Training

I have read the materials in this Manual and have been trained and understand the Anti-Money
Laundering Compliance Program requirements. I have been instructed on the Bank Secrecy Act reporting
and recordkeeping requirements, including the SAR MSB form.

Employees Name: _______________________________________________

Employees Signature: ____________________________________________

Date: __________________________________________________________

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 Independent Review

Every Money Service Business is required by the USA Patriot Act to conduct an independent review of its
compliance program. A senior level employee of the MSB, or another qualified party such as the MSBs
attorney or accountant, may conduct the review. The designated Compliance Officer cannot conduct the
review.

Whoever conducts the review must be an employee who is familiar with the MSBs Compliance Program
and the anti-money laundering requirements for an MSB. The USA Patriot Act does not specify the
frequency of the reviews other than it must be done at least annually.

See Chapter 4 for Certification form.

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 Chapter 2

Money Laundering Overview

All Money Service Businesses who conduct money order sales, cash checks, and send/receive
money transfers MUST comply with all anti-money laundering laws and regulations applying to them.
Money laundering is defined as the attempt to conceal or disguise the nature, location, source,
ownership, or control of illegally obtained money.

Three Stages of Money Laundering

There are 3 stages of money laundering. By using these stages a person can make illegal funds appear to
come from a legal or legitimate source.

Placement: A person purchases money orders, travelers checks, prepaid cards, and money transfers, etc. with the
funds from a crime.
Layering: A person moves money from one financial institution to another and changes the form of the money
through multiple transactions making it hard to trace the money to its original source.
Integration: Changing the money into a seemingly legitimate form. (purchasing automobiles, businesses, real estate,
etc.) that can later be sold.

Money Service Business Registration

You are considered a Money Service Business and are governed under the Secrecy Act, USA Patriot Act, and OFAC
if you do any of the following over $1,000.00 per day to any one person. You must register with the IRS on a Money
Service Business Registration Form 107 within 180 days of becoming a MSB. You must renew your MSB registration
by December 31 every other year or when there has been a change of ownership. Blank forms and a renewal
calculator can be found at www.FinCEN.org.

Money Orders Issuer, Seller, or Redeemer (casher) of money orders

Travelers ChecksIssuer, Seller, or Redeemer (casher) of travelers checks

Check Cashing Check cashier

Currency Dealer Currency Dealer

Currency Exchanger Currency Exchanger

Stored Value Issuer, Seller, or Redeemer (casher) of stored value products (ex: prepaid credit cards)

Money Transfer Service Wire transfers (in any amount)

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USA Patriot Act Anti-Money Laundering Compliance Program

The USA Patriot Act requires all MSBs to adopt a written anti-money laundering compliance program that is
reasonably designed to ensure proper recordkeeping and reporting of certain transactions, and to prevent your
business from being used to launder money. Your anti-money laundering compliance plan must at a minimum
include:

A. Internal Policies, procedures, and controls for:

Verifying customer identification
Filing reports
Creating and retaining records
Responding to law enforcement requests

B. The designation of a Compliance Officer who is responsible for assuring that:

Policies and procedures are followed
Procedures are updated as follows
Training and education are provided
Reports are properly filed

C. Ongoing employee training program that:

Explains policies and procedures
Teaches how to identify suspicious activity

D. An independent review of the anti-money laundering program:

The review should take place as needed and be as thorough as needed based on the risks of your
business.
The review can be performed by one of your employees, but not the Compliance Officer.

This plan will provide the necessary information to be in compliance with the USA Patriot Act.

OFAC Office of Foreign Assets Control

OFAC is part of the U.S. Department of the Treasury and is responsible for enforcing U.S. government sanctions
against countries, organizations and individuals. Sanctions programs normally involve blocking assets to further
national security. Many sanctioned individuals (SDNs) are known drug dealers and terrorists. All U.S. entities are
prohibited from doing financial transactions with the SDNs.
Your money transfer company should be checking the names of individuals against the list of SDNs. A list is
available on the U.S. Department of the Treasury website. www.ustreas.gov/offices/enforcement/ofac.

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 Chapter 3

Recordkeeping
An MSB business must keep the following records at your place of business for a period of 5 years:

1. FinCEN form 107 Registration of Money Services Business Registration filed with FinCEN within 180
days of becoming a Money Service Business and by December 31st every other year after that.
2. Any response received from FinCEN to the filing of the completed FinCEN form 107 Registration of
Money Service Business form.
3. All currency transactions over $10,000.00 (including consumer fees). CTR Form 104 file within 15
days.
4. All suspicious activity over $2,000.00 including structuring. SAR Form 109 file within 30 days.
Structuring is when a customer purchases less than amount to fill out paperwork more than once a day
for a combine total of $2,000.00 to avoid giving information requested.

Agent must log all money order sales to one person in one day over $2,000.00 in the money order sales
log. The following information needs to be logged:

Verify:
Customers name and address
Valid government issued, photo ID (Dr. License, Passport, Alien Identification Card, Etc.)

Record:
Customers name and address
Type of ID provided, ID#, or alien ID#
Customers Social Security number
Customers date of birth
Transaction date
Serial number sold
Amount of transaction

ALL FORMS CAN BE FILED AT WWW.FinCEN.ORG AND MUST BE KEPT FOR 5 YEARS

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Suspicious Activity Reporting

You must file a Suspicious Activity Report within 30 days if the transaction or group of transactions involves at least
2,000.00 and is believed to be suspicious.

To be suspicious you must believe one of the following:

o Involves funds from illegal activity or is intended to hide funds derived from illegal activity.
o Is structured to avoid recordkeeping or reporting requirements
o Has no business or apparent lawful purpose, or
o Facilitates criminal activity

Here are some samples of suspicious activity;

o A customer asks an employee how to avoid reporting requirements.

o A customer threatens or bribes an employee to avoid providing ID
o A customer refuses to provide ID
o A customer (or group of customers working together) purchases money orders just below the
recordkeeping or reporting threshold with the purpose of evading either of these. This practice is
called structuring
o A customer conducts transactions that are unusually large based on their history, employment, or
level of income.

It is illegal to help a person structure their purchase in a way that avoids the record keeping requirements. Employees
should be alert to attempts by customers to convince them to allow the structuring of money order purchases that
allows them to avoid record keeping procedures. The employees of (store name) ________________________________
will not tell, imply, or knowingly allow a person to structure money order purchases in a way that will result in failure to
need or elimination of collecting ID or filing reports.

Currency Transaction Reports

You must file a Currency Transaction Report on any transaction or group of transactions greater than
10,000.00 in one day (including agent fees).

Civil and Criminal Penalties

Criminal penalties can be severe and for an individual be $500,000.00 and as much as 10 years of
imprisonment.

Independent Review

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The USA Patriot Act requires that all Money Service Businesses conduct an Independent review annually to verify
their compliance plan is adequate. The independent review should be done by the owner, manager, or employee of
the business as long as it is not done by the Compliance Officer.

If the person that does the review is not an employee of the company must they be familiar with the policies and
procedure requirements that apply to MSBs.

CERTIFICATION OF INDEPENDENT REVIEW

I have completed an independent review of ________________________________. Among other things, this review
focused on the requirements of the USA Patriot Act and the Bank Secrecy Act. The results of my review are that I find
_________________________________________________ anti-money laundering plan:

Acceptable____________________________________________________________________________________

Acceptable, but recommend the following enhancements________________________________________________

Unacceptable for the following reasons

______________________________________________________________

Signature of person conducting review ____________________________________________

Printed Name ________________________________________________________________

Title ________________________________________________________________________

Date ________________________________________________________________________

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 RGA Requirements for Agents Outline

Agent requirements:

Register with the IRS as a Money Service Business at FinCEN.gov

Have available at the store a compliance plan with a Compliance Officer named
o Compliance Officer is responsible for making sure AML laws are being adhered to.
o Train store personnel handling Money Order sales with AML procedures at least annually.

Keep a log for 5 years for any group of money orders sold to one customer in any 24 hr period over
2,000.00. Log should include:
o Customers Name
o Customers Address
o Customers Social Security number or Alien ID number
o Customers date of birth
o Date of Money Orders purchased
o Amount of money orders purchased
o Government issued ID Number (Dr. license, Passport, Alien ID, etc)
o If money orders are purchased for a third party you must also provide the log information for both
parties.

You MUST complete the log information BEFORE you complete the transaction

File a CTR (Currency Transaction Form) at www.bsaefile.fincen.treas.gov website for any customer with a
combined total of transactions (including the fees) of 10,000.00 in a 24 hr. period (must file within 15 days)

File a SAR (Suspicious Activity Report) at www.bsaefile.fincen.treas.gov website, when both a transaction is
over 2,000.00 and it is suspicious. (Must file within 30 days). Suspicious activity is hard to define, because
there are so many circumstances surrounding a transaction. You should suspect a customer if;
o The customer asks how to structure the transactions to avoid having to provide ID.
o If funds involved in transactions come from illegal activity or funds are intended to hide illegal
activity.
o Customer has no business or apparent reason for transaction
o Transaction facilitates criminal activity

You may file a suspicious activity report below 2,000.00 but it is not required

IT IS ILLEGAL TO TELL YOUR CUSTOMER YOU HAVE FILED A SAR OR CTR

A person filing a SAR is protected from civil penalties by law

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