Plain-language guides on BSA/AML requirements for money services businesses — what the rules actually require, what examiners actually check, and how to build a program that holds up.
A complete walkthrough of what a BSA/AML compliance program must contain under 31 CFR 1022.210 — the four pillars, what each section must include, how examiners evaluate it, and the most common gaps that cause examination findings.
IRS examiners use IRM 4.26.9 to evaluate your compliance program. This guide walks through what they request, what they review, and what causes examination findings — so you know exactly what you're preparing for.
De-risking is a real problem for MSBs. Banks close accounts when they can't assess your compliance risk. This guide explains what banks are looking for and what documentation keeps your account open.
Most MSBs know they need to register with FinCEN — but registration is just the starting point. This guide covers what FinCEN registration triggers, what ongoing obligations it creates, and what the penalties are for non-compliance.
Don't wait for the guide. Our template packages give you a complete, exam-ready BSA/AML compliance program — download and customize today.
The numbers every MSB compliance officer needs to know.
Currency transactions in cash above $10,000 in one business day require a Currency Transaction Report (FinCEN Form 112). MSBs cannot exempt any customer from this requirement.
Suspicious activity at or above $2,000 must be reported via a Suspicious Activity Report (FinCEN Form 111). Lower than the $5,000 threshold that applies to banks. Check cashers and currency exchangers are not required to file SARs.
Money transmitters must collect and transmit information on transmittals of funds of $3,000 or more under 31 CFR 1010.410(f). Applies to money transmitters only — not check cashers or money order sellers.
There is no dollar threshold for OFAC compliance. Every transaction, every customer, every counterparty must be screened against the SDN list and other OFAC sanctions lists — regardless of amount.
Cash purchases of monetary instruments (money orders, cashier's checks, traveler's checks) between $3,000 and $10,000 must be logged under 31 CFR 1010.415. Applies to check cashers and money order sellers.
BSA records — CTRs, SARs, CIP records, transaction logs, and training records — must be retained for a minimum of 5 years. Some records have longer retention requirements. Independent review reports must also be retained.