Money Service Business Groups Best Practices for AML/CTF Programs

Money Service Businesses (MSBs) are defined in the United States as money transmitters under various federal and state laws and regulations. As such, the U.S. Financial Crimes Enforcement Network (FinCEN) requires that MSBs develop, implement, and maintain a risk-based anti-money laundering (AML) and combating the financing of terrorism (CFT) program. With the recent fallout of the cryptocurrency exchange FTX Inc., U.S. regulators are analyzing the compliance programs of MSBs to determine compliance with AML requirements, among other areas. Review this article, which explores best practices and AML/CTF compliance programs requirements, set forth by key MSB trade associations for businesses transacting in the United States.

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Related Content        

• Licensed Money Services Businesses
  Access this practice note for a comprehensive outline of the federal and state laws and AML regulations that limit the scope of the activities and operations of MSBs, including money transmitters.

• Money Services State Law Survey
  Gain key insight into relevant state laws and regulations for each of the 50 U.S. states and territories regarding MSB licensing, transmission, and operating requirements.

• FinCEN Guidance for Cryptocurrency Firms
  Review the FinCEN published guidance on cryptocurrency and understand the regulatory AML guidelines for digital asset transmission.

• Customer Identification and Due Diligence Requirements Pursuant to the Bank Secrecy Act
  Explore customer identification, due diligence, and customer identification program (CIP) statutory and regulatory requirements required as part of a MSB’s risk-based AML/CFT compliance program.

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