Leading MSB Industry Associations Unveil Anti-Money Laundering Best Practices

WASHINGTON, DC (May 11, 2022) — The Electronic Transactions Association (ETA); INFiN, a Financial Services Alliance; the Money Services Business Association (MSBA); and The Money Services Round Table (TMSRT) today announced the release of Best Practices for U.S. Money Services Businesses: Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) Compliance Programs. The members of these industry associations represent the full range of Money Services Businesses (MSBs), from large firms offering a wide variety of services around the globe to small firms offering remittance services in niche corridors, industry incumbents, and fintechs. The Best Practices reflect the MSB industry’s commitment to ensuring a safe and compliant environment for providing non-bank financial services amid rapidly evolving threats to the U.S. financial system.

Initiated by MSB industry members, this comprehensive set of Best Practices for MSBs is the culmination of an extensive, cross-sector effort with two goals. The first, to refine MSB AML/CFT compliance standards to safeguard the financial system, and the second, to address the challenge of forced de-risking (the cancellation of banking services to entire business lines, rather than on a case-by-case basis).

“The industry effort to identify and distribute Best Practices for U.S. Money Services Businesses: Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) Compliance Programs marks a significant advancement in efforts to combat de-risking. [The Conference of State Bank Supervisors] (CSBS) commends the trade associations for taking this step and encourages continued dialogue surrounding this issue.”
—John W. Ryan, President & CEO, CSBS

To advance MSB compliance standards, MSB industry members received feedback from regulators, law enforcement agencies, banks, and policymakers to create a set of guidelines representing the MSB industry’s views on prudent approaches to MSB AML/CFT compliance. These guidelines recognize that an MSB’s compliance obligations should be viewed and applied according to the risk associated with its respective size, services, products offered, geographic footprint, and business model.

All MSBs depend on access to banking services. To address forced de-risking of MSBs, the authors believe banks will be encouraged to provide services to MSBs that adhere to these Best Practices. In fact, banks and banking associations played an integral role in drafting the MSB Best Practices.

Further, MSBs continue to grow, reflecting the rising demand from consumers and businesses for essential, beneficial, and innovative products and services in the U.S. and globally. According to CSBS, state licensed MSBs conduct more than $1.8 trillion in transactions annually[1] and are an essential part of the financial services industry, for banks, commercial customers, and consumers. Accordingly, the trade associations involved in crafting the MSB Best Practices are committed to their ongoing review, updating, and implementation to meet the evolving needs of the marketplace and broader financial system.

ETA, INFiN, MSBA, and TMSRT acknowledge the regulatory and law enforcement agencies, financial institutions, money services businesses, trade organizations, banks, public policy bodies, and numerous individuals that provided feedback on this document and help the industry-driven effort to improve compliance with AML/CFT regulations. Discussions and collaboration among Bank Secrecy Act Advisory Group (BSAAG) members were instrumental, and informed the development of these Best Practices through cross-sector discussions. The importance of codes of conduct, best practices, and educational initiatives were recently noted in the Government Accounting Office (GAO) report as an area that could lead to improvements in risk management regarding AML/CFT and sanctions issues.[2]

Read the Best Practices for U.S. Money Services Businesses at the websites of each industry associations below.

About ETA
The Electronic Transactions Association (ETA) is the world’s leading advocacy and trade association for the payments industry. Our members span the breadth of significant payments and fintech companies, from the largest incumbent players to the emerging disruptors in the U.S and in more than a dozen countries around the world. ETA members make commerce possible by processing approximately $22.5 trillion annually in purchases worldwide and deploying payments innovation to merchants and consumers.

About INFiN
INFiN, a Financial Services Alliance, is the leading national trade association representing the diverse and innovative consumer financial services industry. INFiN represents more than 350 companies, operating approximately 8,000 locations throughout the United States and online. INFiN members deliver critical products and services – including check cashing, pre-paid cards, money transfers, electronic bill payments, and small-dollar consumer loans, among others – to meet U.S. consumers’ ever-changing needs and expectations.

For more information on INFiN, go to https://infinalliance.org/

About MSBA
The Money Services Business Association, Inc. (MSBA) is a trade association comprised of non-bank money services industry participants, including licensed money transmitters their agents/authorized delegates, payment card issuers and distributors, payment processors, international remittance companies, bill payment companies, mobile payment application providers, payment aggregators, virtual currency exchanges and administrators, money order issuers, e-Wallet providers and other similar money services providers. MSBA works to support the continuous improvement of the non-bank financial service industry, tracking and providing feedback on legislative and regulatory changes, striving to increase awareness of the benefits of our members' services, and how transactions are processed in a more secure manner. MSBA actively fosters communication and collaboration between industry participants, Federal and State regulators, and law enforcement.

For more information on MSBA, go to https://www.msbassociation.org

About TMSRT
Founded in 1988 as an information sharing and advocacy group for the nation’s leading non-bank money transmitters, The Money Services Round Table (TMSRT) is currently comprised of RIA Financial Services, Sigue Corporation, American Express Travel Related Services Company, Inc., Western Union Financial Services, Inc., and MoneyGram Payment Systems, Inc. These companies offer a variety of funds transmission services including bill payments and funds transfers (domestic and international) through retail points of sale, the internet, and mobile devices, as well as the sale and reloading of stored value products and other money transmission services. TMSRT supports the implementation and maintenance of effective laws and rules reasonably drafted to ensure that the financial system, and customers who use the services of money transmitters, are appropriately protected.

PRESS CONTACTS
Scott Talbott
Electronic Transactions Association
[email protected]
(202) 297-1035

Edward P. D’Alessio, Executive Director
INFiN, a Financial Services Alliance
[email protected]
(202) 327-9708

Kathy Tomasofsky, Executive Director
Money Services Business Association
[email protected]
(201) 781-2590

Adam J. Fleisher
The Money Services Round Table
[email protected]
(202) 776-2027

[1] See “2020 NMLS Money Services Businesses Report” (2020).

[2] GAO 22-104792, “Bank Secrecy Act: Views on Proposals to Improve Banking Access for Entities Transferring Funds to High-Risk Countries” (2021).