AML --- Anti Money Laundering etc ...

[YouKnowWho@YouKnowWhere]

Where or who is enforcing these "anti money laundering" requirements for
coin shops. It all started after September 11th .. but I listened to an ex
IRS agent recently giving a speech to coin shop owners saying the need "a
written plan" [a couple of thousand dollars paid to HIM] and you need a
yearly audit [about $7k paid to him] ... Basically what I want to know is
where is it written .. or where is the IRS law that says coin shops are
required to do this ? Apparently ICTA is saying that this ex-IRS agent is
the only man for the job ..

Thanks.
--

[oly]

On Jan 10, 12:09 pm, "YouKnowWho@YouKnowWhere"

All of the following is written on the assumption that you are going
to attempt to comply. I can see where many shops might not worry at
all...

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++++++++++++++++++++++++++++++++++++

Anti-money laundering laws DO APPLY to coin dealers (not just banks,
but all thinsg defined as "Money Service Businesses, or "MSBs"); but
there are quite a few ways to be in compliance. There is no one way
to go. Seven thousand is absolutely ridiculous.

There are "four Pillars" of BSA/AML compliance:

Basically, you need to have a system to identify (and perhaps
aggregate) a customer's cash transactions of $10,000.01 and over;

You need to designate somebody in the company as the "official" BSA/
AML officer;

You need a written policy (you can get a template for $50 or less,
your banker might give you a copy of his);

and you need to train employees at least once a year on the
requirements of the BSA/AML laws...

you should probably get a copy of the Currency Transaction Reporting
form (and instructions) and a Copy of the Suspicious Activity
Reporting form (and isntructions).

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
+++++++++++++++++++++++++++++++++++

BSA/AML DOES NOT APPLY to checks, money orders, wire transfers (at the
coin dealer's level at least). BSA/AML is all about CASH GREENIES and
cash greenies ONLY (plus maybe some exotic forms of gold).

If you wish to be fully in compliance with the Bank Secrecy Act/ Anti-
money laundering laws, rules and regulations, I think $300 to $400 the
first year would get you all the documents and employee training you
need.

You might enjoy attending a BSA/AML school just to hear all the "war
stories" that get told about slimy customers and devious or inept
bankers.

Finally, I must advise that no coin dealer will ever get asked about a
transaction, UNLESS it's something that you SHOULD have been
SUSPICIOUS about in the first place. When things are too good to be
true (or legitimate) they probably are. The federales have de-
emphasized BSA/AML in recent months, as the financial cisis has taken
up all of their resources.

oly

[oly]

A Division of the IRS called "FinCEN" (Financial Crimes Enforcement
Network) and the FBI would be the parties who would most likely
contact or visit a coin dealer in regards to an AML enquiry. For
banks, the principal point of contact would be the primary Federal
Regulator (OCC, OTS, FRB or FDIC).

FinCEN is the outfit that accumulates Currency Transaction Reports,
Suspicious Activity Reports, and certain information on Americans'
foreign travel and the purchase of luxury items. They have done so
for many years, BTW.

oly

[YouKnowWho@YouKnowWhere]

"oly" <oly...@aol.com> wrote in message
news:80354e20-15a7-4231...@s9g2000prg.googlegroups.com...

oly

thanks much. I didn't see a need for an annual audit of our records if we
have filled out all the proper forms, got social security numbers etc and we
feel confident that no matter what agency walks through the door, we can
hand them all our records with no worry. the ex IRS person said that it was
necessary, but why wouldn't he when it puts $8500 in his pocket. .

Thing is .. I never knew of any of these requirements a few years ago. I
think it was ICTA that made me aware. I just wonder how many coin shops
throughout the country don't know about the manual etc .. I would think that
it would be up to the IRS to send notices of any changes directly to the
coin shops .. If a sales tax or other tax changes, you always see notices in
with your payment booklet or the blank tax forms they mail you.