AML & BSA Compliance
Last Updated: 2025-02-17 Status: Complete
Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) compliance is mandatory for payment facilitators. These regulations require robust transaction monitoring, suspicious activity reporting, and comprehensive compliance programs.
Quick Reference
| Requirement | Threshold | Deadline |
|---|---|---|
| SAR (known suspect) | $5,000 | 30 days |
| SAR (no suspect) | $25,000 | 30-60 days |
| CTR | > $10,000 | Same day |
| SAR for insider abuse | Any amount | 30 days |
What is AML/BSA?
BSA (Bank Secrecy Act)
The BSA requires financial institutions to:
- Maintain records of cash transactions
- Report suspicious activities
- Implement AML compliance programs
- Conduct customer due diligence
AML (Anti-Money Laundering)
AML refers to the broader set of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income.
Section Contents
Money Laundering
- Three stages of money laundering
- Common patterns and red flags
- PayFac-specific risks
SAR Reporting
- SAR filing requirements and thresholds
- CTR requirements
- Filing procedures and deadlines
Transaction Monitoring
- Monitoring systems and rules
- Alert investigation workflow
- Documentation requirements
Quiz
- Self-assessment questions
PayFac AML Obligations
Payment facilitators have specific AML responsibilities:
Five Pillars of AML Compliance
| Pillar | Requirement |
|---|---|
| 1 | Written AML policies and procedures |
| 2 | Designated compliance officer |
| 3 | Ongoing employee training |
| 4 | Independent testing/audit |
| 5 | Risk-based customer due diligence |
Key Reporting Thresholds
Suspicious Activity Reports (SARs)
| Situation | Threshold | Filing Deadline |
|---|---|---|
| Known suspect identified | $5,000 | 30 days |
| No suspect identified | $25,000 | 30-60 days |
| Insider abuse | Any amount | 30 days |
| Money laundering suspected | $5,000 | 30 days |
| MSB point of sale | $2,000 | 30 days |
Currency Transaction Reports (CTRs)
| Transaction Type | Threshold | Filing |
|---|---|---|
| Cash transactions | > $10,000 | Same business day |
| Aggregate cash (same person) | > $10,000 | Same business day |
PayFac Applicability
Many PayFacs qualify for the payment processor exemption if they:
- Facilitate payments for goods/services
- Operate through clearance and settlement systems
- Have agreements with merchants
Consult compliance counsel to determine your status.
Money Laundering Red Flags
| Category | Red Flags |
|---|---|
| Transaction Patterns | Round-dollar amounts, just under thresholds, rapid movement |
| Geographic | High-risk countries, unusual locations |
| Business | Inconsistent with business type, sudden volume changes |
| Customer Behavior | Reluctance to provide information, multiple accounts |
Learn more: Money Laundering Patterns
Compliance Program Components
Written Policies
| Policy Area | Contents |
|---|---|
| AML Policy | Overall program description |
| CIP/KYC | Customer identification procedures |
| Transaction Monitoring | Monitoring rules and thresholds |
| SAR Procedures | Filing criteria and workflow |
| Training | Employee training requirements |
Compliance Officer
| Responsibility | Description |
|---|---|
| Program oversight | Manage AML program |
| SAR decisions | Approve SAR filings |
| Regulatory liaison | Interface with examiners |
| Training | Ensure staff training |
| Updates | Keep program current |
Training Requirements
| Audience | Frequency | Topics |
|---|---|---|
| All employees | Annual | AML basics, red flags |
| Compliance staff | Quarterly | Deep dive, updates |
| New hires | At onboarding | Full program overview |
| Board | Annual | Program status, risks |
Recordkeeping Requirements
| Record Type | Retention Period |
|---|---|
| SAR filings | 5 years |
| CTR filings | 5 years |
| Customer identification | 5 years after account closure |
| Transaction records | 5 years |
| AML training records | 5 years |
Related Topics
- Merchant Monitoring - Transaction monitoring
- Fraud Prevention - Fraud vs. AML monitoring
- Incident Response - Reporting requirements
Onboarding Context:
- KYC/KYB Requirements - Due diligence starts at onboarding with identity verification
- Beneficial Ownership - UBO identification for AML compliance