Announcing the NMTA's "3-In-1"
      Agent Supervision Package!

From the Daily News Clippings of March 17, 2016:

On March 14, 2016 we reported that FinCEN had issued their Guidance on Existing AML Program Rule Compliance Obligations for MSB Principals with Respect to Agent Monitoring. I wrote in that day's DNC:

"As with so many things to do with compliance, one of the main challenges in agent supervision is the cost of doing an agent review. I would be very interested to hear your ideas on this question: how your company deals with the cost of agent reviews and what solutions you may have come up with."

In response to this challenge, I have developed the NMTA 3-In-1 Agent Supervision Package, that offers money transmitter principals a training, customized manual, independent review and risk assessment, for $495 per agent.

Your personnel will do the site visit, under my supervision. Licensees who wish to know more about this offer should call me without delay.

If any compliance wonk should tell you a credible review cannot be done for $495, tell them to call me, and I will teach them how.

IRS visits to agent locations have increased in recent years. I believe that, with this interpretive Guidance, FinCEN is sending us a further clear signal to all money transmitter principals: get your act together now, if it isn't tightened up already.