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Government Transactions and Anti-Money Laundering Compliance
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Key Points for Financial Institutions
When dealing with government transactions, financial institutions must adhere to specific regulations to prevent money laundering. Here are some key points to consider:
Transaction Reporting Requirements
- When a federal, state, or local government official conducts a transaction over $10,000 in currency, the financial institution only needs to obtain and record identifying information for the agency they are working with, not the individual.
- The financial institution should still record the name of the government official conducting the transaction.
Additional Information Requirements
- For purchases over $3,000 in currency, the financial institution should also record the date of birth of the government official.
Independent Reviews for Anti-Money Laundering Programs
The Financial Crimes Enforcement Network (FinCEN) has issued guidance on independent reviews for money services businesses’ anti-money laundering programs. These reviews aim to:
- Test internal controls and transactional systems to identify problems and weaknesses.
- Be conducted by an officer or employee, not a certified public accountant or outside consultant.
Review Scope and Frequency
The scope and frequency of the review will depend on the risk assessment of the money services business. Regular reviews are essential to ensure ongoing compliance with anti-money laundering regulations.