Money Services Business MSB

1
Money Services Business (MSB)

• BYU Controllers Meeting
• July 18, 2002

2
Money Services Business (MSB)

• Record Keeping Requirements
• Transmittal of funds
• Currency Exchange
• Issuance or Sale of Monetary Instruments
• Extensions of Credit over 10,000
• Transfers of funds to or from U. S.
• States reporting requirements

3
Money Services Business (MSB)

• Suspicious Transactions
• Illegally derived funds
• No apparent business purpose
• Evasion of laws or regulations

4
Money Services Business (MSB)

• Written anti-money laundering program
• Internal policies, procedures, and controls to
  insure compliance
• Designation of a Compliance Officer

5
Money Services Business (MSB)

• Ongoing employee training
• Independent Audit Function
• Enforcement by IRS and Commissioner of Customs

6
Money Services Business (MSB)

• Fines of 100,000 to 500,000 levied against the
  institution and any officer, director, or
  employee for willfull disregard of any of the
  requirements

7
(No Transcript)
8
Money Services Business (MSB)

• Currency Dealer or Exchanger
• Check Casher
• Issuer of or Seller/Redeemer of
• Travelers Checks
• Money Orders
• Stored Value (Signature Card)
• Money Transmitter (any amount)

9
Money Services Business (MSB)Check Casher

• Providing check cashing services in excess of
  1,000 per person per day in one or more
  transactions
• Same limits apply to cashing our own
  institutional checks.

10
Money Services Business (MSB)Travelers
Checks/Money Orders

• Redeeming, Issuing or cashing travelerss checks
  in excess of 1,000 per person per day

11
Money Services Business (MSB)Stored Value
Accounts

• Stored value accounts (Signature Cards)account
  balance in excess of 1,000

12
Money Services Business (MSB)Currency Dealer or
Exchanger or Money Transmitter

• Dealing in currency as a trade or business or
  exchanging of one countrys currency for another
  in excess of 1,000 per person per day
• Acceptance of funds and transmitting through a
  financial institution to another party.

13
Money Services Business (MSB)Reporting
Obligations

• All entities (even non MSBs)
• Currency transactions in excess of 10,000
• Transportation of currency or monetary
  instruments in excess of 10,000 out of U. S.
• Reports of foreign bank accounts