FinCEN Issues Interim Regulations Concerning Anti-Money Laundering Programs for Operators of Credit Card Systems and Money Services Businesses.
As discussed in the April 23, 2002 issue of the Alert, the Financial Crimes Enforcement Network of the U.S. Department of Treasury ("FinCEN") issued four interim final rules ("AML Rules") implementing Section 352 of the USA PATRIOT Act. One of the AML Rules ("Operator AML Rule") focuses upon anti-money laundering ("AML") programs of "operators of credit card systems" ("Operator" or "Operators"). Another of the AML Rules ("MSB AML Rule") focuses on the AML programs ("AML Programs") of money services businesses ("MSB" or "MSBs"). Both Operators and MSBs must establish AML Programs by July 24, 2002. An AML Program must include, at a minimum: (1) the establishment of internal policies, procedures, and controls; (2) the designation of a compliance officer; (3) an ongoing employee training program; and (4) an independent audit function to test
