Examination information, faqs, and resources for Washington Check Cashers and Payday Lenders.
The Manager’s Questionnaire is delivered to the licensee just before an examination that is routine. The Manager’s Questionnaire are going to be finished by the licensee and came back towards the Department ahead of the assessment.
Responses to typical questions regarding exams carried out by DFI.
What exactly is a cash solutions company (MSB)? Have always been we an MSB?If you may be certified beneath the Check Cashers and Sellers Act, you may be an MSB beneath the Bank Secrecy Act. Check always Casher and Seller licensees are MSBs when they practice cash transmission, check cashing (only when the licensee cashes checks over $1,000 for almost any one individual in every 1 day), check selling (only when the licensee offers checks or cash instructions over $1,000 for almost any anyone in virtually any 1 day), or attempting to sell saved value (as long as the licensee offers saved value over $1,000 for almost any one individual in every 1 day). What performs this suggest for you personally? If you should be an MSB, your company could be susceptible to extra guidelines and laws.
Many MSBs have to register utilizing the Financial Crimes Enforcement Network (FinCEN). The enrollment is filed on FinCEN Form 107.
- Be commensurate utilizing the dangers posed by the positioning and measurements of, in addition to nature and level of the services that are financial by, the income solutions company.
- Be written down, making readily available for assessment to your Department associated with the Treasury as well as other regulatory agencies upon demand.
- At the absolute minimum utilize policies, procedures, and interior controls fairly built to ensure conformity with AML laws, including needs for:
- Confirming consumer information
- Filing reports (such as for example Currency Transaction Reports and activity that is suspicious)
- Creating and records that are retaining
- Giving an answer to police force needs
- Designate a conformity officer in order to guarantee compliance that is day-to-day this system.
- Offer regular separate review to monitor and continue maintaining a program that is adequate. The range and regularity associated with the review will probably be commensurate aided by the chance of the economic solutions supplied because of the cash solutions company. This review could be carried out by an employee or officer of the cash solutions company as long as the reviewer isn’t the designated conformity officer.
- Offer AML conformity training for workers concerning their duties beneath the system, including trained in the detection of dubious deals. paperwork showing that appropriate training ended up being supplied to any or all workers, including copies of training materials utilized to perform working out needs to be distributed around the Department.