Introductory BSA AML Examiner School Manual Palm Springs 2019

MSBs Can Help Fight Money Laundering

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A customer who breaks down a single large transaction into smaller transactions after being informed that a report must be filed or a record made. A customer who presents different identification each time a transaction is conducted. A customer who spells his/her name differently or uses a different name each time he/she initiates or receives a money transfer or purchases traveler’s checks. Any individual or group that bribes or attempts to bribe an MSB employee not to file any required reporting forms or not to create a record entry required by law or company policy. Any individual or group that forces or attempts to force an MSB employee not to file any required reporting forms or create a record required by law or company policy.

A customer who receives payment of multiple money transfers that appear to have been purchased in a "structured" manner – organized in a way to evade reporting and recordkeeping requirements. – By the same send customer, each transfer in an amount just under $3,000 (or other relevant threshold). – By multiple send customers initiated at one MSB location within minutes of each other, each transfer in an amount just under $3,000 (or other relevant threshold). A customer cashing multiple instruments (money orders, traveler’s checks, cashiers’ checks, foreign drafts) that appear to have been purchased in a structured manner (e.g. each in an amount below $3,000).

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