Introductory BSA/AML Examiner School, Atlanta, CA

MSBs Can Help Fight Money Laundering

What Should MSBs Look For? (Cont.) Attempts to Evade BSA Reporting or Recordkeeping Requirements Customers may try to keep their transactions just below the reporting or recordkeeping thresholds, such as: A customer or group of customers who attempt to hide the size of a large cash transaction by breaking it into multiple, smaller transactions by, for example, conducting the smaller transactions— – At different times on the same day. – With different MSB cashiers on the same day or different days. – At different branches of the same MSB on the same or different days. A customer or group of customers who conduct several similar transactions ■ ■

over several days, staying just under reporting or recordkeeping limits each time. For example, the customer may: – Purchase money orders with cash just under $3,000 over several days. – Purchase traveler’s checks with cash just under $3,000 over several days. – Initiate multiple money transfers to the same receiver, each transfer in an amount under $3,000, over several days. A customer who is reluctant to provide information needed for a reporting or recordkeeping requirement, whether required by law or by company policy. A customer who is reluctant to proceed with a transaction after being informed that a report must be filed or a record made. ■ ■

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