Meet AML Compliance Requirements

1. Register your business with FinCEN.gov by going to the BSA E-Filing site.
2. Click on Becoming a BSA E-Filer.
3. Click on Institution.
4. Go through all four steps and create a user in step 2.
5. Once you generate a user, you can register on the site by going to MSB-107 form and filling out the form electronically.

If you need help, you can contact our compliance team.

You need to develop written policies and procedures that address the following:

• A process that verifies the identification of customer cashing the check.
• A process for filing reports (CTR/SAR reports).
• Guidelines for detecting suspicious activity.
• Guidelines for creating and retaining records.
• Procedures for responding to law enforcement requests.

Assign an employee to be the compliance officer. Typically, this person is the owner or the manager of the store. The compliance officer is responsible for assuring the following:

• Your store properly files necessary reports and retains proper records
• The compliance program is updated to reflect current requirements and guidance by the Government
• You provide necessary training and education to all employees who cash checks

EmagineNET’s Compliance Program Binder contains a template for designating and training the compliance officer.

The designated compliance officer should train all employees who cash checks on the following matters:

• Basics of the BSA regulations.
• Your store’s policies and procedures for cashing checks.
• Steps to detect suspicious money laundering activity.
• Record keeping requirements for checks cashed above a certain amount.
• Steps to file CTR and SAR forms.

EmagineNET’s Compliance Program Binder contains presentations that can be used to provide training to all the employees.

Have any owner or employee of the business – other than the designated compliance officer – conduct regular reviews of the check-cashing operation. The review should focus on the following:

• Ensure the compliance program is up-to-date.
• Ensure all employees who cash checks are adequately trained.
• Ensure proper records are being maintained as per the store’s compliance programs.
• Ensure CTR and SAR reports are being filed appropriately.

EmagineNET’s Compliance Program Binder contains detailed check lists to help conduct these reviews.