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My money services business understands that Bank Secrecy Act regulations (31 C.F.R. Part 103) require, among other things, implementing a written anti-money laundering program and maintaining records of certain transactions. Because of the nature of my business, I would prefer to…
FinCEN has extended for another two years a conditional exception to the strict operation of the "Travel Rule" (31 CFR 103.33(g)). The Travel Rule requires a financial institution to include certain information in transmittal orders relating to transmittals of funds of 3,000 or more. This…
The Financial Crimes Enforcement Network (FinCEN) receives numerous questions concerning compliance with the Bank Secrecy Act (BSA) recordkeeping requirement found in 31 C.F.R. §103.29. This section requires financial institutions to verify a customer’s identity and retain…
This serves notice that the Director of the Financial Crimes Enforcement Network (FinCEN) has granted a waiver from civil money penalties for violations of the Bank Secrecy Act, 31 U.S.C. 5314, and its implementing regulation, 31 C.F.R. Part 103.24, to persons who enter into settlement and…
Agents with the Bureau of Alcohol, Tobacco, Firearms and Explosives conducted an investigation into the illegal sale of cigarettes that led to the indictment of 13 defendants. Cigarettes that were purchased in a low tax state were sold in a high tax state without the payment of taxes in either…
In March 2002, the FBI opened an investigation into the activities of a hawala dealer in the western United States. Limited initial information received from a citizen complaint prompted a query of the BSA database. The query yielded 30 SARs and 13 CTRs, which were instrumental in identifying…
An individual walked into a Pennsylvania bank and opened one individual account and two business accounts. The individual then walked across the street to a different bank and opened three additional accounts. Unbeknownst to the individual, these two banks were in the process of merging and his…
A Suspicious Activity Report filing prompted a Bureau of Immigration and Customs Enforcement investigation into the activities of a subject from another country. The Suspicious Activity Report alleged that after an initial account opening deposit, the subject had structured deposits exceeding $…
