If you run a business that facilitates or conducts money transactions, or transactions in other liquid commodities, you are no doubt aware of FinCEN. Rest assured that FinCEN is aware of you, too. And we predict it’s only a short matter of time before their foreshadowing of AML enforcement actions against the cash servicing and transport industry becomes a harsh reality.

The Financial Crimes Enforcement Network (FinCEN) is the arm of the U.S. Treasury charged with investigation and enforcement of Bank Secrecy Act provisions intended to block the financial sources of illegal and terrorist organizations. Traditionally, the BSA applied to common financial institutions like banks and credit unions. But as banks began to offload services to third party vendors and the number of money-related businesses like check cashers and wire transfers proliferated, the BSA has been applied to an ever-wider array of businesses.

Most of these newer businesses are collectively known as Money Service Businesses (MSB). Businesses that transmit money, issue money orders, cash checks, deal in foreign currencies, or a number of other types of transactions, are required to register with FinCEN and maintain an effective Anti-Money Laundering (AML) program. … Continue reading