MSB Compliance Resources
Plain-language guides on BSA/AML requirements for money services businesses — what the rules actually require, what examiners actually check, and how to build a program that holds up.
How to Write an AML Compliance Program for Your MSB
A complete walkthrough of what a BSA/AML compliance program must contain under 31 CFR 1022.210 — the four pillars, what each section must include, how examiners evaluate it, and the most common gaps that cause examination findings.
What Happens During an IRS BSA Examination?
IRS examiners use IRM 4.26.9 to evaluate your compliance program. This guide walks through what they request, what they review, and what causes examination findings — so you know exactly what you're preparing for.
Why Banks Close MSB Accounts (And How to Keep Yours)
De-risking is a real problem for MSBs. Banks close accounts when they can't assess your compliance risk. This guide explains what banks are looking for and what documentation keeps your account open.
MSB Registration: What It Means and What It Requires
Most MSBs know they need to register with FinCEN — but registration is just the starting point. This guide covers what FinCEN registration triggers, what ongoing obligations it creates, and what the penalties are for non-compliance.
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Key regulatory thresholds for MSBs
The numbers every MSB compliance officer needs to know.
CTR Filing Threshold
Currency transactions in cash above $10,000 in one business day require a Currency Transaction Report (FinCEN Form 112). MSBs cannot exempt any customer from this requirement.
SAR Filing Threshold (MSBs)
Suspicious activity at or above $2,000 must be reported via a Suspicious Activity Report (FinCEN Form 111). Lower than the $5,000 threshold that applies to banks. Check cashers and currency exchangers are not required to file SARs.
Travel Rule (Money Transmitters)
Money transmitters must collect and transmit information on transmittals of funds of $3,000 or more under 31 CFR 1010.410(f). Applies to money transmitters only — not check cashers or money order sellers.
OFAC Screening Threshold
There is no dollar threshold for OFAC compliance. Every transaction, every customer, every counterparty must be screened against the SDN list and other OFAC sanctions lists — regardless of amount.
$10,000
Monetary Instrument Sales Log
Cash purchases of monetary instruments (money orders, cashier's checks, traveler's checks) between $3,000 and $10,000 must be logged under 31 CFR 1010.415. Applies to check cashers and money order sellers.
Recordkeeping Requirement
BSA records — CTRs, SARs, CIP records, transaction logs, and training records — must be retained for a minimum of 5 years. Some records have longer retention requirements. Independent review reports must also be retained.