FinCEN not only fined the owner of a Michigan MSB*, now closed, $12,000, for a total lack of AML/CFT on customers who sent money to Yemen, but it barred him from ever being involved, in any way, in any entity that it defines as a financial institution, ever again. That's pretty strong, but look at what he allowed to occur at his company:
(1) Sending dollar amounts inconsistent with family support payments.
(2) Large amounts sent within a short period of time.
(3) Large dollar amounts, sent without any apparent business or lawful purpose.
(4) Transactions sent to multiple beneficiaries in different locatiobs in yemen.
(5) Multiple sends, within one business day, below the recordkeeping threshold.
SAR filings ? Forget about it. There was ZERO compliance. Will more financial professionals be forever barred from the industry, when they violate AML/CFT regulations ? We cannot say, but we will be watching.
Readers who wish to review the complete text of the FinCEN Assessment can find it here.
*Ali Al Duais; the MSB was King Mail & Wireless, Inc. A successor MSB by this individual was known as Al Malik Wireless, Inc.