BSA/AML Student Exercises Dec. 2022

B. Printing an order form from the http://www.msb.gov website and faxing it to 1-800-773-8356 or mail to: Money Services Business Program Office P.O. Box 39 Vienna, VA 22183 or; C. Calling in an order to 1-800-386-6329. A branch office of an MSB is not required to file its own registration form. A person or entity defined as an MSB is generally required to register with FinCEN within 180 days after the day that the person or entity is established as an MSB. Therefore, it is possible that an MSB will seek banking services before completing the registration process with FinCEN, but still be in full compliance with the law, After initial registration, a MSB must renew its registration every two years by December 31St for as long as the MSB continues to meet the MSB definition. There is currently no provision or procedure to allow an MSB to de-register. The only option for a business that has ceased to operate as an MSB, or that has registered incorrectly, is to desist from renewing its registration The following MSBs are not required to register with FinCEN as an MSB: 1. A business that is a money services business solely because it serves as an agent of another MSB; 2. A business that is an MSB solely as an issuer, seller or redeemer of stored value; 3. The U.S. Postal Service; and 4. Agencies of the United States, of any state, or of any political subdivision of any state. It is the responsibility of the BSA Department to confirm that an MSB customer is an agent that is not required to register with FinCEN by obtaining a copy of contracts and agreements with the principal MSB and/or obtain similar information from the customer's company website. This documentation is to be placed in the Bank's MSB file for historical and compliance reference. Bank Secrecy Act/Anti-Money Laundering Risk Assessment Guidelines While the extent to which the Bank should perform further due diligence beyond the minimum compliance obligations set forth above will be dictated by the level of risk posed by the individual customer, it is not the case that all MSBs will always require further due diligence. Accordingly, as with any business account, in determining how much, if any, further due diligence would be required for any MSB customer, it is the responsibility of the BSA Department, to consider the following information: 1. Types of products and services offered by the MSB. In order to properly assess risks, it is the responsibility of the Bank to know the categories of money services engaged in by the particular MSB accountholder. In addition, the Bank determines whether the MSB is a "principal' (with a fleet of agents) or is itself an agent of another MSB. Other relevant considerations include whether or not the MSB is a new or established operation, and whether or not money services are the customer's primary or ancillary business (such as a grocery store that derives a small fraction of its overall revenue from cashing checks). 2. Location(s) and market(s) served by the MSB. Money laundering risks within an MSB can vary widely depending on the locations, customer bases and markets served by the MSB. You should consider whether markets served are domestic or international, or whether services are targeted to local residents or broad markets. For example, a convenience store that only cashes payroll

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