Money Services
Businesses
"Among the most examined businesses under the BSA"
Regulatory Body
FinCEN (primary), State Money Transmitter Regulators
Examiner
IRS BSA Examiners, State Banking Departments
Training Frequency
Annual minimum; quarterly recommended for high-volume operations
Regulatory Landscape
Money Services Businesses are among the most heavily regulated and frequently examined entities under the Bank Secrecy Act. FinCEN defines MSBs broadly including money transmitters, check cashers, currency dealers and exchangers, issuers and sellers of money orders and traveler's checks, and prepaid access providers. Each category carries specific AML program requirements, and examiners look closely at whether training is role-appropriate, documented, and current.
BSA/AML Obligations
The following obligations apply to Money Services Businesses under the Bank Secrecy Act and applicable FinCEN guidance.
Written AML Program
A written AML program tailored to the MSB's specific products, services, customers, and geographic locations.
Currency Transaction Reports (CTRs)
File CTRs for cash transactions exceeding $10,000 by or through the MSB in a single business day.
Suspicious Activity Reports (SARs)
File SARs for transactions of $2,000 or more that involve suspected money laundering or other financial crimes.
Customer Identification
Verify customer identity for transactions above applicable thresholds and maintain records as required.
Recordkeeping
Maintain records of transactions, customer identification, and training for a minimum of five years.
Ongoing Training
Provide role-appropriate AML training to all personnel involved in covered transactions.
Risk Indicators
Red Flags to Watch For
- Customer structures transactions just below CTR threshold (structuring)
- Customer unable or unwilling to provide identification
- Frequent large cash transactions with no apparent business purpose
- Customer sends or receives funds to/from high-risk jurisdictions
- Multiple customers sending funds to the same beneficiary
- Customer appears nervous or coached during transaction
- Transactions inconsistent with customer's stated business or occupation
- Rapid movement of funds with no apparent economic purpose
Curriculum
Training Topics Covered
- BSA/AML program requirements for MSBs
- CTR filing thresholds, exemptions, and procedures
- SAR filing obligations and the $2,000 threshold
- Structuring recognition and reporting
- Customer identification and recordkeeping
- High-risk jurisdictions and correspondent relationships
- Role-specific red flags by transaction type
- FinCEN enforcement actions and lessons learned
Common Examination Findings
These are the most frequently cited deficiencies in Money Services Businesses AML programs. Addressing them proactively is the difference between a clean examination and a finding.
Training not documented or not verifiable
Training not role-appropriate for frontline staff
SAR filing delays or failures for known suspicious activity
CTR exemptions not properly documented
AML policy not updated to reflect current products or locations
Get Money Services Businesses AML Training
Industry-specific, NAMLC-verified training through Soflo Consulting and AML Training Center.