Introductory BSA/AML Examiner School, Providence, RI

MSBs • Greater than $1,000 for any person on any day in currency, monetary or other instruments in one or more transactions: o Dealers in Foreign Exchange o Check Cashers o Issuer or seller of traveler’s checks or money orders • Greater than $10,000 to any person during any one day and has not implemented policies and procedures reasonably adapted to prevent such a sale: o Seller of prepaid access

MSBs

• No activity threshold applies to the definition of money transmitter.

• A person who engages as a business in the transfer of funds is an MSB as a money transmitter, regardless of the amount of money transmission activity.