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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

RequirementThresholdDeadline
SAR (known suspect)$5,00030 days
SAR (no suspect)$25,00030-60 days
CTR> $10,000Same day
SAR for insider abuseAny amount30 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

PillarRequirement
1Written AML policies and procedures
2Designated compliance officer
3Ongoing employee training
4Independent testing/audit
5Risk-based customer due diligence

Key Reporting Thresholds

Suspicious Activity Reports (SARs)

SituationThresholdFiling Deadline
Known suspect identified$5,00030 days
No suspect identified$25,00030-60 days
Insider abuseAny amount30 days
Money laundering suspected$5,00030 days
MSB point of sale$2,00030 days

Currency Transaction Reports (CTRs)

Transaction TypeThresholdFiling
Cash transactions> $10,000Same business day
Aggregate cash (same person)> $10,000Same 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

CategoryRed Flags
Transaction PatternsRound-dollar amounts, just under thresholds, rapid movement
GeographicHigh-risk countries, unusual locations
BusinessInconsistent with business type, sudden volume changes
Customer BehaviorReluctance to provide information, multiple accounts

Learn more: Money Laundering Patterns

Compliance Program Components

Written Policies

Policy AreaContents
AML PolicyOverall program description
CIP/KYCCustomer identification procedures
Transaction MonitoringMonitoring rules and thresholds
SAR ProceduresFiling criteria and workflow
TrainingEmployee training requirements

Compliance Officer

ResponsibilityDescription
Program oversightManage AML program
SAR decisionsApprove SAR filings
Regulatory liaisonInterface with examiners
TrainingEnsure staff training
UpdatesKeep program current

Training Requirements

AudienceFrequencyTopics
All employeesAnnualAML basics, red flags
Compliance staffQuarterlyDeep dive, updates
New hiresAt onboardingFull program overview
BoardAnnualProgram status, risks

Recordkeeping Requirements

Record TypeRetention Period
SAR filings5 years
CTR filings5 years
Customer identification5 years after account closure
Transaction records5 years
AML training records5 years

Onboarding Context:

References

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