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Anti-Money Laundering Compliance |
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| Dear Banrural Corp Agent: |
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| As a Banrural Corp agent helping prevent money
laundering by complying with federal recordkeeping
and reporting laws in very important. Non-compliance
with the Bank Secrecy Act, the USA Patriot Act, and
other federal laws may lead to your termination as
an agent and also possibly facing civil and criminal
penalties as well as fines. |
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| To help you understand how to stop money
laundering and comply with federal requirements, the
following Anti-Money Laundering Compliance Guide has
been prepared by Banrural Corp. |
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| It is important that you read the information
provided in the Guide so you can become familiar
with the federal money laundering laws. |
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Anti-Money Laundering Guide
Spanish Version |
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| Anti-Money Laundering Program |
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| The USA Patriot Act required that by July 24,
2002, 90 days after the required compliance date,
that all MSBs implement an “appropriate anti-money
laundering program.” This program mush be in writing
an include but not be limited to the following: |
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- Internal anti-money laundering policies,
procedures and controls.
- An anti-money laundering compliance officer
must be appointed.(It is important that this
person be responsible and knowledgeable of
everything required to stay in compliance with
these laws.
- All employees that help customers or process
Banrural Corp transactions must be continually
trained on money laundering.
- An independent audit function to test your
anti-money laundering program.
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| Using our Guide to help you write your
anti-money laundering controls, procedures and
policies in strongly encouraged. Since the Guide
covers what you need to know about money laundering
and how to prevent it, using it in your
employee-training program is also encouraged. |
| For use in your Anti-Money Laundering Compliance
Program there are several forms included in the
Guide. These forms include a compliance officer
designation form, employee training verification
forms, and compliance program acceptance forms.
These forms are not to be returned to Banrural Corp
or sent to the Frederal government, they are for
your records only. See the Guide for some samples. |
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| Suspicious Activity Reporting |
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| Suspicious Activity Report By Money Services
Business(“SAR-MSB”) are required by federal law in
reporting suspicious activity by an employee or a
customer. Whenever transactions totaling $2,000 or
more are attempted or conducted at your location you
must file a report when you know or suspect that the
transaction: (1) involves money obtained from
illegal activity, (2) is designed to avoid one of
the reporting requirements, or (3) has no business
or apparent lawful purpose and you know of no
reasonable explanation for the transaction. Failure
to file a SAR-MSB form intentionally can constitute
as a criminal act. For more information on the SAR-MSB,
visit the federal government’s Web site at
www.msb.gov. |
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| Registration |
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| The type of money services business that you
provide will determine whether or not you need to
fill out a Money Services Business Registration
Form. The federal government refers to businesses
like Banrural Corp and their agents as "Money
Services Business" (MSB). |
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| Existing Law |
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| The Currency Transaction Report (CTR) and the
recordkeeping and identification requirements that
apply to cash purchases of money orders of $3,000 to
$10,000, and the recordkeeping requirements that
apply to any money transfer of $3,000 or more are
discussed in the Guide. Remind your employees of how
important it is to fully comply with these reporting
and recordkeeping requirements, as part of your
anti-money laundering training. |
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| U.S. economic sanctions and trade programs are
administered by the Office of Foreign Assets
Control, also known as OFAC and all businesses in
the U.S. are subject to OFAC regulations, which
include a prohibition on doing business with certain
governments, as well as individuals who have been
identified by OFAC as terrorists, drug traffickers
or other specially designated persons. (More
information about OFAC is available at OFAC's Web
site at www.treas.gov/ofac/.) |
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| Please read the Guide carefully. Banrural Corp
is committed to fight money laundering, and knows
that you too will share this determination to
prevent our money transfers, as well as your
business, from being used for illegal purposes.
Money laundering is a crime that can lead to serious
penalties for you and Banrural Corp, as well as
damage the character of both of our businesses.
Together, we can help prevent money laundering from
occurring. |