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    Finance (Money Services Business)

 

  • Consultation for money services business (MSBs), such as money transmitters, check cashers, dealers in foreign exchange (formerly known as currency exchangers and currency dealers), sellers and providers of prepaid access, stored-value companies, and issuers, redeemers and sellers of money orders and traveler’s checks.

 

  • MSB typical tasks, such as: obtaining and maintaining Money Transmitter Licenses (MTLs); FinCEN registration within 180 days of when the MSB was established; state licensing applications and issues, state and federal compliance audits, including IRS and BSA examinations; state and federal enforcement actions, including those seeking to impose fines and revoke licenses; obtaining and maintaining a surety bond; background checks; preparing a business plan; verification of permissible investments; verification of minimum net worth; OFAC licensing issues; corporate actions, including local qualification of out-of-state companies, provision of registered agents, drafting and amending corporate governance documents; anti-money laundering (AML), Bank Secrecy Act (BSA) and Know Your Customer (KYC) compliance; responses to law enforcement and grand jury subpoenas and investigations; obtaining and maintaining the New York State separate license for digital currency businesses –“BitLicense” – required to engage in any virtual currency business activity.

 

  • MSB record-keeping, such as estimates of the expected value of the business over the next year, a list of all the agents which are operating in the United States, a copy of the original registration form, copies of currency transaction reports (CTR) – FinCEN Form 112, suspicious activity reports, and information collected through the Know Your Customer (KYC) and Customer Identification (CID) programs.

 

  • MSB reporting, such as providing: CTRs to FinCEN about any transaction or set of aggregate transactions that amount to more than $10,000 on behalf of the same person during the business day, including information about the parties involved, taxpayer identification, as well as verification of the customer’s identity; suspicious activity reports (FinCEN Form 111) if an MSB knows or may suspect that a transaction is related to illegal activity, or has been designed to hide money gained through an illegal activity.

 

  • Design and implementation of an MSB AML compliance program to enable the MSB to identify the underlying purpose of a given transaction and verify certain information about the parties involved.

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    Last updated 200714_2147

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