Money services businesses do not need to keep separate bank accounts for their different business lines to comply with the Bank Secrecy Act, according to a U.S. Treasury Department ruling.
Companies that only transfer funds to buy or sell currencies and commodities are not money transmitters subjected to the Bank Secrecy Act, the U.S. Treasury Department said on Wednesday.
The processing of checks and drafts from foreign institutions does not by itself constitute a correspondent relationship, FinCEN said in the guidance.
As any compliance officer knows, vetting a banking correspondent relationship is no simple matter. Initial evaluations of another institution's anti-money laundering program can be long, the cost high and reviews perpetual. Three consultants talk about best practices in correspondent banking.