Profile_bird

Hey there! MSBCompliance is using Twitter.

Twitter is a free service that lets you keep in touch with people through the exchange of quick, frequent answers to one simple question: What's happening? Join today to start receiving MSBCompliance's tweets.

Already using Twitter
from your phone? Click here.

MSBCompliance

  1. Heading out to annual FiSCA conference.
  2. Day 3 of National Money Transmitters Assn conference. Glad to see Wells Fargo Bank represented here.
  3. National Money Transmitter Assn in Miami. Excellent turnout in a rough economy. www.NMTA.us
  4. 1- Domestic Agents. Periodic on site review, policies & training, agent receivables & losses, AML risk of agent
  5. Paying agent due diligence should include sharing of written compliance audit and financial statements, if available
  6. 2- Paying Agents. Adequate due diligence needed. Potential danger of large concentration w foreign paying agents.
  7. 3- Net Worth. Losses impacting capital. Danger of no longer meeting net worth requirements. Difficulty raising new capital.
  8. 4- Operating Losses. Revenues down + agent receivables. Expenses stagnant or increasing.
  9. 5- Financial stresses. Laying off people in wrong areas- A/R, compliance, sales. Lower volumes. Access to credit.
  10. 6- AML Policies. Risk assessment, policy tie in to written practices, agent program, law enforcement requests
  11. 7- AML Issues. Monitoring, reporting, timely and accurate reports, SAR narratives, Agent lists
  12. Regulatory reports - MSBs can't share confidential report but regulators happy to talk with their bankers
  13. 8- Bank accounts. Maintaining; new opportunities w consolidation; concentration risk
  14. 9- Disaster recovery plans and tests- reasonable, risk based, tested, works
  15. 10- Timely and accurate regulatory reports... Keep us informed, don't surprise us
  16. Money transmitter safety and soundness top ten from regulators...
  17. 1/4 world believes time=money, 3/4 believes relationships=money
  18. Multiple requests from multi-state remitters for more states to participate in / accept joint reviews
  19. Grateful for strong presence of state regulators, FinCEN, IRS, ICE, DEA at conference
  20. Regulatory expectations for risk assessment- enterprise and agent- continuing to strengthen