Introductory BSA AML Examiner School Manual Palm Springs 2019

Money Transmitters

Business Model – Agent included

Money Transmitter

Receiving Agent

Branch or Agent

Sender

Recipient

7

MSB Examinations

• IRS examines for BSA compliance

• States examine for financial safety and soundness, as well as BSA compliance – More emphasis on financial safety and soundness – May not examine for all financial services • IRS and States use the Bank Secrecy Act/Anti-Money Laundering Examination Manual for Money Services Businesses

8