source:
  type: regulation
  id: fincen-msb-1022
  authority: "31 CFR Part 1022 \u2014 Anti-money laundering rules for money services businesses (FinCEN, Bank Secrecy Act)"
  description: "31 CFR Part 1022 sets the AML-program (\xA71022.210) and suspicious-activity-reporting (\xA71022.320) obligations for money services\
    \ businesses. FinCEN guidance treats convertible-virtual-currency exchangers and administrators as money transmitters, so these are the federal\
    \ AML obligations that apply to crypto money-services businesses."
obligations:
- id: csh-ob-53779373a5a55f25
  description: The program shall be commensurate with the risks posed by the location and size of, and the nature and volume of the financial
    services provided by, the money services business.
  type: do
  section: 1022.210(b)
  audit_question: Can the lender demonstrate that the program shall be commensurate with the risks posed by the location and size of, and the
    nature and volume of the financial services provided by, the money services business?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-53779373a5a55f25
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(b) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: The program shall be commensurate with the risks posed by the location and size of, and the nature and volume of the financial
      services provided by, the money services business.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program account for the risks posed by the location, size, and nature/volume of the MSB's financial services \u2014\
    \ i.e., is the AML program scaled to the MSB's risk profile?"
  file_review: Review the program's risk basis against the MSB's actual location/size/service mix; the compliance person judges whether the program
    is commensurate with the risk.
  judgment: true
- id: csh-ob-5d1ec5273bdd7a2b
  description: The program shall be in writing, and a money services business shall make copies of the anti-money laundering program available
    for inspection to the Department of the Treasury upon request.
  type: do
  section: 1022.210(c)
  audit_question: Can the lender demonstrate that the program shall be in writing, and a money services business shall make copies of the anti-money
    laundering program available for inspection to the Department of the Treasury upon request?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-5d1ec5273bdd7a2b
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(c) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: The program shall be in writing, and a money services business shall make copies of the anti-money laundering program available
      for inspection to the Department of the Treasury upon request.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: Does the program ensure the AML program is in writing and that copies are made available to Treasury for inspection on request?
  file_review: Confirm a current written program exists and that there is a defined process to produce it to Treasury on request.
  judgment: false
- id: csh-ob-21ef0040b0f77f52
  description: 'At a minimum, the program shall:'
  type: do
  section: 1022.210(d)
  audit_question: Can the lender demonstrate that at a minimum, the program shall:?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-21ef0040b0f77f52
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(d) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: 'At a minimum, the program shall:'
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-495ca3014acddd4f
  description: 'Policies, procedures, and internal controls developed and implemented under this section shall include provisions for complying
    with the requirements of this chapter including, to the extent applicable to the money services business, requirements for:'
  type: do
  section: 1022.210(i)
  audit_question: "Can the lender demonstrate that policies, procedures, and internal controls developed and implemented under this section shall\
    \ include provisions for complying with the requirements of this chapter including, to the extent applicable to the money services business,\
    \ requir\u2026?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-495ca3014acddd4f
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(i) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: 'Policies, procedures, and internal controls developed and implemented under this section shall include provisions for complying
      with the requirements of this chapter including, to the extent applicable to the money services business, requirements for:'
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-60252e4c74c5a016
  description: A money services business that is a provider or seller of prepaid access must establish procedures to verify the identity of a
    person who obtains prepaid access under a prepaid program and obtain identifying information concerning such a person, including name, date
    of birth, address, and identification number. Sellers of prepaid access must also establish procedures to verify the identity of a person
    who obtains prepaid access to funds that exceed $10,000 during any one day and obtain identifying information concerning such a person, including
    name, date of birth, address, and identification ...
  type: do
  section: 1022.210(iv)
  audit_question: "Can the lender demonstrate that a money services business that is a provider or seller of prepaid access must establish procedures\
    \ to verify the identity of a person who obtains prepaid access under a prepaid program and obtain identifying information concerning such\
    \ a pe\u2026?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-60252e4c74c5a016
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(iv) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: A money services business that is a provider or seller of prepaid access must establish procedures to verify the identity
      of a person who obtains prepaid access under a prepaid program and obtain identifying information concerning such a person, including name,
      date of birth, address, and identification number. Sellers of prepaid access must also establish procedures to verify the identity of a
      person who obtains prepaid access to funds that exceed $10,000 during any one day and obtain identifying information concerning such a person,
      including name, date of birth, address, and identification
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program account for prepaid-access ID requirements \u2014 verifying the identity of persons obtaining prepaid access\
    \ under a prepaid program (capturing name, DOB, address, ID number), and additionally for sellers verifying identity where prepaid access\
    \ to funds exceeds $10,000 in any one day?"
  file_review: For sampled prepaid-access enrollments (and any >$10,000/day prepaid-access loads), confirm the identity verification and identifying-information
    capture.
  judgment: false
- id: csh-ob-a76212802245a2f7
  description: 'Designate a person to assure day to day compliance with the program and this chapter. The responsibilities of such person shall
    include assuring that:'
  type: do
  section: 1022.210(2)
  audit_question: Can the lender demonstrate that designate a person to assure day to day compliance with the program and this chapter?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-a76212802245a2f7
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(2) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: 'Designate a person to assure day to day compliance with the program and this chapter. The responsibilities of such person
      shall include assuring that:'
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: Does the program designate a named person responsible for day-to-day AML compliance, with the (d)(2) responsibilities assigned?
  file_review: Confirm a named compliance person is designated and the (d)(2) responsibilities are documented for that role.
  judgment: false
- id: csh-ob-4b240f44a6e242f7
  description: Provide education and/or training of appropriate personnel concerning their responsibilities under the program, including training
    in the detection of suspicious transactions to the extent that the money services business is required to report such transactions under this
    chapter.
  type: do
  section: 1022.210(3)
  audit_question: "Can the lender demonstrate that provide education and/or training of appropriate personnel concerning their responsibilities\
    \ under the program, including training in the detection of suspicious transactions to the extent that the money services business is required\
    \ to rep\u2026?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-4b240f44a6e242f7
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(3) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Provide education and/or training of appropriate personnel concerning their responsibilities under the program, including
      training in the detection of suspicious transactions to the extent that the money services business is required to report such transactions
      under this chapter.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program provide education/training of appropriate personnel on their AML responsibilities \u2014 including detection\
    \ of suspicious transactions to the extent the MSB must report them?"
  file_review: Review training materials and completion records for appropriate personnel; confirm suspicious-transaction-detection training is
    included.
  judgment: false
- id: csh-ob-ae14005338ccc712
  description: Provide for independent review to monitor and maintain an adequate program. The scope and frequency of the review shall be commensurate
    with the risk of the financial services provided by the money services business. Such review may be conducted by an officer or employee of
    the money services business so long as the reviewer is not the person designated in paragraph (d)(2) of this section.
  type: do
  section: 1022.210(4)
  audit_question: Can the lender demonstrate that provide for independent review to monitor and maintain an adequate program?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-ae14005338ccc712
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(4) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Provide for independent review to monitor and maintain an adequate program. The scope and frequency of the review shall be
      commensurate with the risk of the financial services provided by the money services business. Such review may be conducted by an officer
      or employee of the money services business so long as the reviewer is not the person designated in paragraph (d)(2) of this section.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: Does the program provide for an independent review (scope and frequency commensurate with risk) to monitor and maintain program
    adequacy, conducted by someone other than the designated compliance person?
  file_review: Confirm an independent review was performed by a reviewer other than the (d)(2) compliance person; the compliance person judges
    whether the review's scope and findings were adequate.
  judgment: true
- id: csh-ob-a2d3a2b4fdbadc3e
  description: Compliance date. A money services business must develop and implement an anti-money laundering program that complies with the requirements
    of this section on or before the later of July 24, 2002, and the end of the 90-day period beginning on the day following the date the business
    is established.
  type: do
  section: 1022.210(e)
  audit_question: Can the lender demonstrate that compliance date?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-a2d3a2b4fdbadc3e
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(e) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Compliance date. A money services business must develop and implement an anti-money laundering program that complies with
      the requirements of this section on or before the later of July 24, 2002, and the end of the 90-day period beginning on the day following
      the date the business is established.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-210.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program account for the \xA71022.210(e) compliance date \u2014 having an AML program in place by the later of July\
    \ 24, 2002 or 90 days after the business was established?"
  file_review: Confirm the AML program's adoption date satisfied the (e) compliance-date deadline (a one-time historical check).
  judgment: false
- id: csh-ob-045eb27fbbc587fb
  description: To the extent that the identification of transactions required to be reported is derived from a review of clearance records or
    other similar records of money orders or traveler's checks that have been sold or processed, an issuer of money orders or traveler's checks
    shall only be required to report a transaction or pattern of transactions that involves or aggregates funds or other assets of at least $5,000.
  type: do
  section: 1022.320(3)
  audit_question: "Can the lender demonstrate that to the extent that the identification of transactions required to be reported is derived from\
    \ a review of clearance records or other similar records of money orders or traveler's checks that have been sold or processed, an issuer\
    \ of money o\u2026?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-045eb27fbbc587fb
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(3) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: To the extent that the identification of transactions required to be reported is derived from a review of clearance records
      or other similar records of money orders or traveler's checks that have been sold or processed, an issuer of money orders or traveler's
      checks shall only be required to report a transaction or pattern of transactions that involves or aggregates funds or other assets of at
      least $5,000.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: Does the program account for the rule that an issuer of money orders/traveler's checks identifying reportable transactions from
    clearance-record review need only report transactions (or patterns) involving or aggregating at least $5,000?
  file_review: Spot-check the clearance-record-derived SAR population; confirm the $5,000 aggregation threshold was applied correctly.
  judgment: false
- id: csh-ob-9a7320ef9c124813
  description: The obligation to identify and properly and timely to report a suspicious transaction rests with each money services business involved
    in the transaction, provided that no more than one report is required to be filed by the money services businesses involved in a particular
    transaction (so long as the report filed contains all relevant facts). Whether, in addition to any liability on its own for failure to report,
    a money services business that issues the instrument or provides the funds transfer service involved in the transaction may be liable for
    the failure of another money services busine...
  type: do
  section: 1022.320(4)
  audit_question: "Can the lender demonstrate that the obligation to identify and properly and timely to report a suspicious transaction rests\
    \ with each money services business involved in the transaction, provided that no more than one report is required to be filed by the money\
    \ services b\u2026?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-9a7320ef9c124813
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(4) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: The obligation to identify and properly and timely to report a suspicious transaction rests with each money services business
      involved in the transaction, provided that no more than one report is required to be filed by the money services businesses involved in
      a particular transaction (so long as the report filed contains all relevant facts). Whether, in addition to any liability on its own for
      failure to report, a money services business that issues the instrument or provides the funds transfer service involved in the transaction
      may be liable for the failure of another money services busine
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program account for the rule that each MSB involved in a transaction bears the suspicious-transaction reporting duty,\
    \ while only one SAR need be filed among the MSBs involved (so long as it contains all relevant facts) \u2014 avoiding both gaps and improper\
    \ reliance on another MSB to file?"
  file_review: For sampled multi-MSB transactions, confirm a complete SAR was filed by one of the involved MSBs and that [LENDER]'s reliance (or
    filing) was documented.
  judgment: true
- id: csh-ob-e1bbebdf27c52228
  description: Where to file. The SAR shall be filed in a central location to be determined by FinCEN, as indicated in the instructions to the
    SAR.
  type: do
  section: 1022.320(2)
  audit_question: Can the lender demonstrate that where to file?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-e1bbebdf27c52228
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(2) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Where to file. The SAR shall be filed in a central location to be determined by FinCEN, as indicated in the instructions
      to the SAR.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-af980900c6703b6a
  description: When to file. A money services business subject to this section is required to file each SAR no later than 30 calendar days after
    the date of the initial detection by the money services business of facts that may constitute a basis for filing a SAR under this section.
    In situations involving violations that require immediate attention, such as ongoing money laundering schemes, the money services business
    shall immediately notify by telephone an appropriate law enforcement authority in addition to filing a SAR. Money services businesses wishing
    voluntarily to report suspicious transactions that...
  type: do
  section: 1022.320(3)
  audit_question: Can the lender demonstrate that when to file?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-af980900c6703b6a
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(3) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: When to file. A money services business subject to this section is required to file each SAR no later than 30 calendar days
      after the date of the initial detection by the money services business of facts that may constitute a basis for filing a SAR under this
      section. In situations involving violations that require immediate attention, such as ongoing money laundering schemes, the money services
      business shall immediately notify by telephone an appropriate law enforcement authority in addition to filing a SAR. Money services businesses
      wishing voluntarily to report suspicious transactions that
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: Does the program track the MSB SAR clock so each SAR is filed within 30 calendar days of initial detection, and ensure that
    violations requiring immediate attention (e.g., ongoing money-laundering schemes) trigger immediate telephone notification to law enforcement
    in addition to the SAR?
  file_review: For each filed MSB SAR, confirm the 30-day timing; for urgent matters, confirm the immediate law-enforcement notification occurred.
  judgment: false
- id: csh-ob-2434369fab34b010
  description: Retention of records. A money services business shall maintain a copy of any SAR filed and the original or business record equivalent
    of any supporting documentation for a period of five years from the date of filing the SAR. Supporting documentation shall be identified as
    such and maintained by the money services business, and shall be deemed to have been filed with the SAR. A money services business shall make
    all supporting documentation available to FinCEN or any Federal, State, or local law enforcement agency, or any Federal regulatory authority
    that examines the money services business f...
  type: do
  section: 1022.320(c)
  audit_question: Can the lender demonstrate that retention of records?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-2434369fab34b010
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(c) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Retention of records. A money services business shall maintain a copy of any SAR filed and the original or business record
      equivalent of any supporting documentation for a period of five years from the date of filing the SAR. Supporting documentation shall be
      identified as such and maintained by the money services business, and shall be deemed to have been filed with the SAR. A money services
      business shall make all supporting documentation available to FinCEN or any Federal, State, or local law enforcement agency, or any Federal
      regulatory authority that examines the money services business f
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program retain, for five years from filing, each MSB SAR copy plus the original (or business-record equivalent) of\
    \ supporting documentation \u2014 identified as such and available to FinCEN/law enforcement/examiners?"
  file_review: For sampled MSB SARs, confirm the retained copy and identified supporting documentation, retained five years from filing.
  judgment: false
- id: csh-ob-834138e2cbab6701
  description: Confidentiality of SARs. A SAR, and any information that would reveal the existence of a SAR, are confidential and shall not be
    disclosed except as authorized in this paragraph (d). For purposes of this paragraph (d) only, a SAR shall include any suspicious activity
    report filed with FinCEN pursuant to any regulation in this chapter.
  type: do
  section: 1022.320(d)
  audit_question: Can the lender demonstrate that confidentiality of SARs?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-834138e2cbab6701
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(d) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Confidentiality of SARs. A SAR, and any information that would reveal the existence of a SAR, are confidential and shall
      not be disclosed except as authorized in this paragraph (d). For purposes of this paragraph (d) only, a SAR shall include any suspicious
      activity report filed with FinCEN pursuant to any regulation in this chapter.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program ensure that an MSB SAR \u2014 and any information that would reveal a SAR's existence \u2014 is kept confidential\
    \ and not disclosed except as authorized in (d)?"
  file_review: Review SAR access controls and any disclosures; confirm no unauthorized disclosure revealing a SAR's existence occurred.
  judgment: false
- id: csh-ob-5b97956bcf3d64ca
  description: 'Rules of Construction. Provided that no person involved in any reported suspicious transaction is notified that the transaction
    has been reported, this paragraph (d)(1) shall not be construed as prohibiting:'
  type: do
  section: 1022.320(ii)
  audit_question: Can the lender demonstrate that rules of Construction?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-5b97956bcf3d64ca
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(ii) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: 'Rules of Construction. Provided that no person involved in any reported suspicious transaction is notified that the transaction
      has been reported, this paragraph (d)(1) shall not be construed as prohibiting:'
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-2a53052eb3bdc26b
  description: Limitation on liability. A money services business, and any director, officer, employee, or agent of any money services business,
    that makes a voluntary disclosure of any possible violation of law or regulation to a government agency or makes a disclosure pursuant to
    this section or any other authority, including a disclosure made jointly with another institution, shall be protected from liability to any
    person for any such disclosure, or for failure to provide notice of such disclosure to any person identified in the disclosure, or both, to
    the full extent provided by 31 U.S.C. 5318(g)(3).
  type: do
  section: 1022.320(e)
  audit_question: Can the lender demonstrate that limitation on liability?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-2a53052eb3bdc26b
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(e) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Limitation on liability. A money services business, and any director, officer, employee, or agent of any money services business,
      that makes a voluntary disclosure of any possible violation of law or regulation to a government agency or makes a disclosure pursuant to
      this section or any other authority, including a disclosure made jointly with another institution, shall be protected from liability to
      any person for any such disclosure, or for failure to provide notice of such disclosure to any person identified in the disclosure, or both,
      to the full extent provided by 31 U.S.C. 5318(g)(3).
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-0e2c131a1daf81e4
  description: Compliance. Money services businesses shall be examined by FinCEN or its delegatees for compliance with this section. Failure to
    satisfy the requirements of this section may be a violation of the Bank Secrecy Act and of this chapter.
  type: do
  section: 1022.320(f)
  audit_question: Can the lender demonstrate that compliance?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-0e2c131a1daf81e4
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.320(f) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Compliance. Money services businesses shall be examined by FinCEN or its delegatees for compliance with this section. Failure
      to satisfy the requirements of this section may be a violation of the Bank Secrecy Act and of this chapter.
  promoted_at: '2026-06-04T20:58:52+00:00'
  promoted_from: 1022-320.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-461f41c06e3fa39d
  canonical_id: csh-ob-461f41c06e3fa39d
  section: 1022.210(a)
  description: "Each money services business, as defined by \xA7 1010.100(ff) of this chapter, shall develop, implement, and maintain an effective\
    \ anti-money laundering program. An effective anti-money laundering program is one that is reasonably designed to prevent the money services\
    \ business from being used to facilitate money laundering and the financing of terrorist activities."
  type: do
  audit_question: Can the money services business demonstrate it has developed, implemented, and maintained an effective written anti-money laundering
    program?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(a) \u2014 Money services business AML program (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: shall develop, implement, and maintain an effective anti-money laundering program. An effective anti-money laundering program
      is one that is reasonably designed to prevent the money services business from being used to facilitate money laundering and the financing
      of terrorist activities.
  promoted_at: '2026-06-04T21:03:38+00:00'
  promoted_from: 1022-210a-fix.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: null
    content_hash: null
  program_review: "Does [LENDER] (as an MSB under \xA71010.100(ff)) develop, implement, and maintain a written AML program reasonably designed\
    \ to prevent the MSB from being used to facilitate money laundering or terrorist financing? (The program IS the control.)"
  file_review: Review the written program; the compliance person judges whether it is reasonably designed for the MSB's ML/TF risk.
  judgment: true
- id: csh-ob-9d624c9b0f332345
  description: "Registration requirement \u2014(1) In general. Except as provided in paragraph (a)(3) of this section, relating to agents, and\
    \ except for sellers of prepaid access as defined in \xA7 1010.100(ff)(7) of this chapter to the extent that they are not already agents,\
    \ each money services business (whether or not licensed as a money services business by any State) must register with FinCEN. Each provider\
    \ of prepaid access must identify each prepaid program for which it is the provider of prepaid access. Each money services business must,\
    \ as part of its registration, maintain a list of its agents as required ..."
  type: do
  section: 1022.380(a)
  audit_question: "Can the lender demonstrate that registration requirement \u2014(1) In general?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-9d624c9b0f332345
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(a) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Each provider of prepaid access must identify each prepaid program for which it is the provider of prepaid access.
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program ensure [LENDER] (as an MSB, whether or not state-licensed) is registered with FinCEN, that each prepaid-access\
    \ provider identifies each prepaid program it provides, and that the agent list is maintained as part of registration \u2014 accounting for\
    \ the agent and prepaid-access-seller carve-outs?"
  file_review: Confirm a current FinCEN MSB registration, the prepaid-program identifications (if any), and the maintained agent list.
  judgment: false
- id: csh-ob-8228c64e11a5e32b
  description: Foreign-located money services business. Each foreign-located person doing business, whether or not on a regular basis or as an
    organized or licensed business concern, in the United States as a money services business shall designate the name and address of a person
    who resides in the United States and is authorized, and has agreed, to be an agent to accept service of legal process with respect to compliance
    with this chapter, and shall identify the address of the location within the United States for records pertaining to paragraph (b)(1)(iii)
    of this section.
  type: do
  section: 1022.380(2)
  audit_question: Can the lender demonstrate that foreign-located money services business?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-8228c64e11a5e32b
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(2) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Foreign-located money services business. Each foreign-located person doing business, whether or not on a regular basis or
      as an organized or licensed business concern, in the United States as a money services business shall designate the name and address of
      a person who resides in the United States and is authorized, and has agreed, to be an agent to accept service of legal process with respect
      to compliance with this chapter, and shall identify the address of the location within the United States for records pertaining to paragraph
      (b)(1)(iii) of this section.
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program account for the foreign-located-MSB rule \u2014 designating a U.S.-resident agent authorized to accept service\
    \ of legal process for chapter-X compliance, and identifying the U.S. location for the (b)(1)(iii) records?"
  file_review: If [LENDER] is a foreign-located MSB, confirm the designated U.S. agent for service of process and the U.S. records location. If
    not foreign-located, confirm the not-applicable determination.
  judgment: false
- id: csh-ob-2d34b4a93b83ff24
  description: "Agents. A person that is a money services business solely because that person serves as an agent of another money services business,\
    \ see \xA7 1010.100(ff) of this chapter, is not required to register under this section, but a money services business that engages in activities\
    \ described in \xA7 1010.100(ff) of this chapter both on its own behalf and as an agent for others must register under this section. For example,\
    \ a supermarket corporation that acts as an agent for an issuer of money orders and performs no other services of a nature and value that\
    \ would cause the corporation to be a money service..."
  type: do
  section: 1022.380(3)
  audit_question: Can the lender demonstrate that agents?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-2d34b4a93b83ff24
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(3) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: For example, a supermarket corporation that acts as an agent for an issuer of money orders and performs no other services
      of a nature and value that would cause the corporation to be a money service
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program correctly account for the agent rule \u2014 a person that is an MSB solely as an agent of another MSB need\
    \ not register, but an entity that conducts MSB activities both on its own behalf and as an agent must register?"
  file_review: Confirm [LENDER]'s registration status is consistent with whether it acts solely as an agent or also on its own behalf (an applicability/classification
    check).
  judgment: false
- id: csh-ob-06b01af66f8786f6
  description: "Registration procedures \u2014(1) In general. (i) A money services business must be registered by filing such form as FinCEN may\
    \ specify with FinCEN (or such other location as the form may specify). The information required by 31 U.S.C. 5330(b) and any other information\
    \ required by the form must be reported in the manner and to the extent required by the form."
  type: do
  section: 1022.380(b)
  audit_question: "Can the lender demonstrate that registration procedures \u2014(1) In general?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-06b01af66f8786f6
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(b) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: (i) A money services business must be registered by filing such form as FinCEN may specify with FinCEN (or such other location
      as the form may specify).
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-6e6d162387179dae
  description: A branch office of a money services business is not required to file its own registration form. A money services business must,
    however, report information about its branch locations or offices as provided by the instructions to the registration form.
  type: do
  section: 1022.380(ii)
  audit_question: Can the lender demonstrate that a branch office of a money services business is not required to file its own registration form?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-6e6d162387179dae
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(ii) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: A branch office of a money services business is not required to file its own registration form. A money services business
      must, however, report information about its branch locations or offices as provided by the instructions to the registration form.
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-ae80a3dd4166364c
  description: Registration period. A money services business must be registered for the initial registration period and each renewal period.
    The initial registration period is the two-calendar-year period beginning with the calendar year in which the money services business is first
    required to be registered. However, the initial registration period for a money services business required to register by December 31, 2001
    (see paragraph (b)(3) of this section) is the two-calendar year period beginning 2002. Each two-calendar-year period following the initial
    registration period is a renewal period.
  type: do
  section: 1022.380(2)
  audit_question: Can the lender demonstrate that registration period?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-ae80a3dd4166364c
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(2) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Registration period. A money services business must be registered for the initial registration period and each renewal period.
      The initial registration period is the two-calendar-year period beginning with the calendar year in which the money services business is
      first required to be registered. However, the initial registration period for a money services business required to register by December
      31, 2001 (see paragraph (b)(3) of this section) is the two-calendar year period beginning 2002. Each two-calendar-year period following
      the initial registration period is a renewal period.
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: Does the program account for the two-calendar-year registration period and each renewal period, so registration coverage never
    lapses?
  file_review: Confirm the current registration covers the applicable two-year period and that renewal cycles have been tracked without lapse.
  judgment: false
- id: csh-ob-25ec3240b69107e0
  description: Due date. The registration form for the initial registration period must be filed on or before the end of the 180-day period beginning
    on the day following the date the business is established. The registration form for a renewal period must be filed on or before the last
    day of the calendar year preceding the renewal period.
  type: do
  section: 1022.380(3)
  audit_question: Can the lender demonstrate that due date?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-25ec3240b69107e0
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(3) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Due date. The registration form for the initial registration period must be filed on or before the end of the 180-day period
      beginning on the day following the date the business is established. The registration form for a renewal period must be filed on or before
      the last day of the calendar year preceding the renewal period.
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program track MSB registration due dates \u2014 initial registration within 180 days of the day after the business\
    \ is established, and each renewal on or before the last day of the calendar year preceding the renewal period?"
  file_review: Confirm the initial registration met the 180-day deadline and that each renewal was filed by its calendar-year-end deadline.
  judgment: false
- id: csh-ob-c9555d187aea4b7b
  description: Events requiring re-registration. If a money services business registered as such under the laws of any State experiences a change
    in ownership or control that requires the business to be re-registered under State law, the money services business must also be re-registered
    under this section. In addition, if there is a transfer of more than 10 percent of the voting power or equity interests of a money services
    business (other than a money services business that must report such transfer to the Securities and Exchange Commission), the money services
    business must be re-registered under this sec...
  type: do
  section: 1022.380(4)
  audit_question: Can the lender demonstrate that events requiring re-registration?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-c9555d187aea4b7b
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(4) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Events requiring re-registration. If a money services business registered as such under the laws of any State experiences
      a change in ownership or control that requires the business to be re-registered under State law, the money services business must also be
      re-registered under this section. In addition, if there is a transfer of more than 10 percent of the voting power or equity interests of
      a money services business (other than a money services business that must report such transfer to the Securities and Exchange Commission),
      the money services business must be re-registered under this sec
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program account for re-registration triggers \u2014 a change in ownership/control requiring state re-registration,\
    \ or a transfer of more than 10 percent of voting power or equity interests (outside the SEC-reporting carve-out)?"
  file_review: For any ownership/control change or >10% equity/voting transfer, confirm re-registration was filed (or the SEC-reporting carve-out
    applied).
  judgment: false
- id: csh-ob-2100ffaab6b37bcb
  description: Persons required to file the registration form. Under 31 U.S.C. 5330(a), any person who owns or controls a money services business
    is responsible for registering the business; however, only one registration form is required to be filed for each registration period. A person
    is treated as owning or controlling a money services business for purposes of filing the registration form only to the extent provided by
    the form. If more than one person owns or controls a money services business, the owning or controlling persons may enter into an agreement
    designating one of them to register the busines...
  type: do
  section: 1022.380(c)
  audit_question: Can the lender demonstrate that persons required to file the registration form?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-2100ffaab6b37bcb
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(c) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Persons required to file the registration form. Under 31 U.S.C. 5330(a), any person who owns or controls a money services
      business is responsible for registering the business; however, only one registration form is required to be filed for each registration
      period. A person is treated as owning or controlling a money services business for purposes of filing the registration form only to the
      extent provided by the form. If more than one person owns or controls a money services business, the owning or controlling persons may enter
      into an agreement designating one of them to register the busines
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-645759f8175e829e
  description: "List of agents \u2014(1) In general. A money services business must prepare and maintain a list of its agents. The initial list\
    \ of agents must be prepared by January 1, 2002, and must be revised each January 1, for the immediately preceding 12 month period; for money\
    \ services businesses established after December 31, 2001, the initial agent list must be prepared by the due date of the initial registration\
    \ form and must be revised each January 1 for the immediately preceding 12-month period. The list is not filed with the registration form\
    \ but must be maintained at the location in the United States ..."
  type: do
  section: 1022.380(d)
  audit_question: "Can the lender demonstrate that list of agents \u2014(1) In general?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-645759f8175e829e
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(d) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: The initial list of agents must be prepared by January 1, 2002, and must be revised each January 1, for the immediately preceding
      12 month period; for money services businesses established after December 31, 2001, the initial agent list must be prepared by the due date
      of the initial registration form and must be revised each January 1 for the immediately preceding 12-month period.
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: Does the program ensure an agent list is prepared and revised each January 1 for the immediately preceding 12-month period,
    maintained at the U.S. location, and available to FinCEN/law enforcement on request?
  file_review: Confirm the current agent list, the January-1 revision cadence, and its maintenance at the required U.S. location.
  judgment: false
- id: csh-ob-65bec49f808043d6
  description: Special rules. Information about agent volume must be current within 45 days of the due date of the agent list. The information
    described by paragraphs (d)(2)(i)(G) and (d)(2)(i)(H) of this section is not required to be included in an agent list with respect to any
    person that is an agent of the money services business maintaining the list before the first day of the month beginning after February 16,
    2000 so long as the information described by paragraphs (d)(2)(i)(G) and (d)(2)(i)(H) of this section is made available upon the request of
    FinCEN and any other appropriate law enforcement agency...
  type: do
  section: 1022.380(ii)
  audit_question: Can the lender demonstrate that special rules?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-65bec49f808043d6
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(ii) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Special rules. Information about agent volume must be current within 45 days of the due date of the agent list. The information
      described by paragraphs (d)(2)(i)(G) and (d)(2)(i)(H) of this section is not required to be included in an agent list with respect to any
      person that is an agent of the money services business maintaining the list before the first day of the month beginning after February 16,
      2000 so long as the information described by paragraphs (d)(2)(i)(G) and (d)(2)(i)(H) of this section is made available upon the request
      of FinCEN and any other appropriate law enforcement agency
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program account for the agent-list special rules \u2014 agent-volume information current within 45 days of the agent-list\
    \ due date, and the (G)/(H) information made available to FinCEN/law enforcement on request for pre-existing agents?"
  file_review: Confirm agent-volume data on the list is current within 45 days of the due date and that (G)/(H) information is retrievable on
    request.
  judgment: false
- id: csh-ob-e4d6c1be203c0b5d
  description: Consequences of failing to comply with 31 U.S.C. 5330 or the regulations thereunder. It is unlawful to do business without complying
    with 31 U.S.C. 5330 and this section. A failure to comply with the requirements of 31 U.S.C. 5330 or this section includes the filing of false
    or materially incomplete information in connection with the registration of a money services business. Any person who fails to comply with
    any requirement of 31 U.S.C. 5330 or this section shall be liable for a civil penalty of $5,000 for each violation. Each day a violation of
    31 U.S.C. 5330 or this section continues cons...
  type: do
  section: 1022.380(e)
  audit_question: Can the lender demonstrate that consequences of failing to comply with 31 U.S.C?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-e4d6c1be203c0b5d
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.380(e) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: Consequences of failing to comply with 31 U.S.C. 5330 or the regulations thereunder. It is unlawful to do business without
      complying with 31 U.S.C. 5330 and this section. A failure to comply with the requirements of 31 U.S.C. 5330 or this section includes the
      filing of false or materially incomplete information in connection with the registration of a money services business. Any person who fails
      to comply with any requirement of 31 U.S.C. 5330 or this section shall be liable for a civil penalty of $5,000 for each violation. Each
      day a violation of 31 U.S.C. 5330 or this section continues cons
  promoted_at: '2026-06-04T21:11:17+00:00'
  promoted_from: 1022-380.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-f00d58c75d0402f5
  description: After July 7, 1987, each dealer in foreign exchange shall secure and maintain a record of the taxpayer identification number of
    each person for whom a transaction account is opened or a line of credit is extended within 30 days after such account is opened or credit
    line extended. Where a person is a non-resident alien, the dealer in foreign exchange shall also record the person's passport number or a
    description of some other government document used to verify his identity. Where the account or credit line is in the names of two or more
    persons, the dealer in foreign exchange shall secure the...
  type: do
  section: 1022.410(a)(1)
  audit_question: "Can the lender demonstrate that after July 7, 1987, each dealer in foreign exchange shall secure and maintain a record of the\
    \ taxpayer identification number of each person for whom a transaction account is opened or a line of credit is extended within 30 days after\
    \ such a\u2026?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-f00d58c75d0402f5
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.410(a)(1) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: After July 7, 1987, each dealer in foreign exchange shall secure and maintain a record of the taxpayer identification number
      of each person for whom a transaction account is opened or a line of credit is extended within 30 days after such account is opened or credit
      line extended. Where a person is a non-resident alien, the dealer in foreign exchange shall also record the person's passport number or
      a description of some other government document used to verify his identity. Where the account or credit line is in the names of two or
      more persons, the dealer in foreign exchange shall secure the
  promoted_at: '2026-06-04T21:11:18+00:00'
  promoted_from: 1022-410.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program ensure that, for each person for whom a transaction account is opened or credit line extended, [LENDER] (as\
    \ a dealer in foreign exchange) secures and retains the TIN within 30 days of account opening / credit-line extension \u2014 and, for non-resident\
    \ aliens, the passport number or other government-ID description?"
  file_review: For sampled foreign-exchange accounts/credit lines, confirm the TIN (or non-resident-alien passport/ID) was secured and retained
    within 30 days.
  judgment: false
- id: csh-ob-ea7b91c6ad26dfbb
  description: The 30-day period provided for in paragraph (a)(1) of this section shall be extended where the person opening the account or credit
    line has applied for a taxpayer identification or social security number on Form SS-4 or SS-5, until such time as the person maintaining the
    account or credit line has had a reasonable opportunity to secure such number and furnish it to the dealer in foreign exchange.
  type: do
  section: 1022.410(2)
  audit_question: "Can the lender demonstrate that the 30-day period provided for in paragraph (a)(1) of this section shall be extended where\
    \ the person opening the account or credit line has applied for a taxpayer identification or social security number on Form SS-4 or SS-5,\
    \ until such ti\u2026?"
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-ea7b91c6ad26dfbb
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.410(2) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: The 30-day period provided for in paragraph (a)(1) of this section shall be extended where the person opening the account
      or credit line has applied for a taxpayer identification or social security number on Form SS-4 or SS-5, until such time as the person maintaining
      the account or credit line has had a reasonable opportunity to secure such number and furnish it to the dealer in foreign exchange.
  promoted_at: '2026-06-04T21:11:18+00:00'
  promoted_from: 1022-410.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
  program_review: "Does the program account for the 30-day extension where the account/credit-line holder has applied for a TIN/SSN on Form SS-4\
    \ or SS-5 \u2014 extending until the holder has a reasonable opportunity to secure and furnish the number?"
  file_review: Spot-check accounts where the 30-day TIN extension was used; confirm a pending SS-4/SS-5 application supported the extension.
  judgment: false
- id: csh-ob-a15d5490f0ff2675
  description: 'Each dealer in foreign exchange shall retain either the original or a microfilm or other copy or reproduction of each of the following:'
  type: do
  section: 1022.410(b)
  audit_question: Can the lender demonstrate that each dealer in foreign exchange shall retain either the original or a microfilm or other copy
    or reproduction of each of the following:?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: triggered
  consequence: ''
  tags:
  - candidate
  - auto-drafted
  - regulator-direct
  - promoted
  canonical_id: csh-ob-a15d5490f0ff2675
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.410(b) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: 'Each dealer in foreign exchange shall retain either the original or a microfilm or other copy or reproduction of each of
      the following:'
  promoted_at: '2026-06-04T21:11:18+00:00'
  promoted_from: 1022-410.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:54:51+00:00'
    content_hash: f7e7c4d2d23e5af1b0f4d57935265db587e6a4683199617d2acd983ad2bda898
- id: csh-ob-21ef0040b0f77f52-enumerated-items
  canonical_id: csh-ob-21ef0040b0f77f52-enumerated-items
  section: "1022.210(d) \u2014 enumerated items (chapeau recall fix)"
  description: The enumerated provisions following the chapeau of 1022.210(d), dropped by the original extraction and restored verbatim from the
    snapshot.
  type: do
  tags:
  - chapeau-recall
  - regulator-direct
  - promoted
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(d) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: (1) Incorporate policies, procedures, and internal controls reasonably designed to assure compliance with this chapter.
    drafter_attestation: "Captured verbatim (whitespace-normalized) from snapshot 6df2b3ce9bcb25cc as the enumerated list immediately following\
      \ the chapeau 'At a minimum, the program shall:'. List boundary captured conservatively \u2014 REVIEW the end boundary before promote."
  judgment: false
  promoted_at: '2026-06-16T19:35:51+00:00'
  promoted_from: fincen-msb-1022-chapeau-recall-v1.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
- id: csh-ob-a76212802245a2f7-enumerated-items
  canonical_id: csh-ob-a76212802245a2f7-enumerated-items
  section: "1022.210(2) \u2014 enumerated items (chapeau recall fix)"
  description: The enumerated provisions following the chapeau of 1022.210(2), dropped by the original extraction and restored verbatim from the
    snapshot.
  type: do
  tags:
  - chapeau-recall
  - regulator-direct
  - promoted
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.210(2) \u2014 Money services business AML program / SAR (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: (i) The money services business properly files reports, and creates and retains records, in accordance with applicable requirements
      of this chapter; (ii) The compliance program is updated as necessary to reflect current requirements of this chapter, and related guidance
      issued by the Department of the Treasury; and (iii) The money services business provides appropriate training and education in accordance
      with paragraph (d)(3) of this section.
    drafter_attestation: "Captured verbatim (whitespace-normalized) from snapshot 6df2b3ce9bcb25cc as the enumerated list immediately following\
      \ the chapeau 'such person shall include assuring that:'. List boundary captured conservatively \u2014 REVIEW the end boundary before promote."
  judgment: false
  promoted_at: '2026-06-16T19:35:51+00:00'
  promoted_from: fincen-msb-1022-chapeau-recall-v1.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
- id: csh-ob-a15d5490f0ff2675-enumerated-items
  canonical_id: csh-ob-a15d5490f0ff2675-enumerated-items
  section: "1022.410(b) \u2014 enumerated items (chapeau recall fix)"
  description: The enumerated provisions following the chapeau of 1022.410(b), dropped by the original extraction and restored verbatim from the
    snapshot.
  type: do
  tags:
  - chapeau-recall
  - regulator-direct
  - promoted
  primary_source:
    tier: 1
    authority: "31 CFR \xA71022.410(b) \u2014 Money services business registration / recordkeeping (FinCEN, Bank Secrecy Act)"
    source_class: fincen
    source_url: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1022
    snapshot_id: 6df2b3ce9bcb25cc
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
    paragraph_quote: (1) Statements of accounts from banks, including paid checks, charges or other debit entry memoranda, deposit slips and other
      credit memoranda representing the entries reflected on such statements; (2) Daily work records, including purchase and sales slips or other
      memoranda needed to identify and reconstruct currency transactions with customers and foreign banks; (3) A record of each exchange of currency
      involving transactions in excess of $1000, including the name and address of the customer (and passport number or taxpayer identification
      number unless received by mail or common carrier) date and amount of the transaction and currency name, country, and total amount of each
      foreign currency; (4) Signature cards or other documents evidencing signature authority over each deposit or security account, containing
      the name of the depositor, street address, taxpayer identification number (TIN) or employer identification number (EIN) and the signature
      of the depositor or of a person authorized to sign on the account (if customer accounts are maintained in a code name, a record of the actual
      owner of the account); (5) Each item, including checks, drafts, or transfers of credit, of more than $10,000 remitted or transferred to
      a person, account or place outside the United States; (6) A record of each receipt of currency, other monetary instruments, investment securities
      and checks, and of each transfer of funds or credit, or more than $10,000 received on any one occasion directly and not through a domestic
      financial institution, from any person, account or place outside the United States; (7) Records prepared or received by a dealer in the
      ordinary course of business, that would be needed to reconstruct an account and trace a check in excess of $100 deposited in such account
      through its internal recordkeeping system to its depository institution, or to supply a description of a deposited check in excess of $100;
    drafter_attestation: "Captured verbatim (whitespace-normalized) from snapshot 6df2b3ce9bcb25cc as the enumerated list immediately following\
      \ the chapeau 'r reproduction of each of the following:'. List boundary captured conservatively \u2014 REVIEW the end boundary before promote."
  judgment: false
  promoted_at: '2026-06-16T19:35:51+00:00'
  promoted_from: fincen-msb-1022-chapeau-recall-v1.yaml
  source_provenance:
    source_id: fincen-msb-1022
    fetched_at: '2026-06-04T20:57:39Z'
    content_hash: sha256:672627676c2d3df520549069fadaad3a28ac22fa6e926df9babafbbda583231a
_promotion_history:
- promoted_at: '2026-06-04T20:58:52+00:00'
  candidate_path: obligations\_remediation\fincen-msb-1022\1022-210.yaml
  candidates_promoted: 9
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- promoted_at: '2026-06-04T20:58:52+00:00'
  candidate_path: obligations\_remediation\fincen-msb-1022\1022-320.yaml
  candidates_promoted: 9
  candidates_skipped_existing: 0
- promoted_at: '2026-06-04T21:03:38+00:00'
  candidate_path: obligations\_remediation\fincen-msb-1022\1022-210a-fix.yaml
  candidates_promoted: 1
  candidates_skipped_existing: 0
- promoted_at: '2026-06-04T21:11:17+00:00'
  candidate_path: obligations\_remediation\fincen-msb-1022\1022-380.yaml
  candidates_promoted: 12
  candidates_skipped_existing: 0
- promoted_at: '2026-06-04T21:11:18+00:00'
  candidate_path: obligations\_remediation\fincen-msb-1022\1022-410.yaml
  candidates_promoted: 3
  candidates_skipped_existing: 0
- promoted_at: '2026-06-04T21:11:18+00:00'
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  candidates_promoted: 0
  candidates_skipped_existing: 0
- promoted_at: '2026-06-16T19:35:51+00:00'
  candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\chapeau-recall\fincen-msb-1022-chapeau-recall-v1.yaml
  candidates_promoted: 3
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- promoted_at: '2026-06-16T19:38:23+00:00'
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  candidates_promoted: 0
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- promoted_at: '2026-06-16T19:39:11+00:00'
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  candidates_promoted: 0
  candidates_skipped_existing: 3
