A money service business agreed to cease its operations and surrender its registration to the Financial Crimes Enforcement Network (FinCEN) for making more than 8,000 transfers to Yemen without doing any anti-money laundering reviews.
Michigan-based Adam Service was also fined $12,000 Friday for not meeting the Bank Secrecy Act’s requirements.
Since 2007, Adam Service transmitted 1,400 wires per year to Yemen, a high-risk country for money laundering and terrorist activity, FinCEN said.
The service failed to review any of the transactions for suspicious activity.
The owner of the business, Saleh H. Adam, admitted to ignoring his Bank Secrecy Act obligations “because he would lose customers if he asked them for identification or asked questions about their transactions.”
Adam also admitted he knew his customers deposited funds on behalf of others and would pool funds to transmit a lump sum.
The Bank Secrecy Act requires MSBs to develop and implement a written AML program that, at a minimum:
- incorporates policies, procedures and internal controls reasonably designed to assure ongoing compliance;
- designates an individual responsible to assure day-to-day compliance with the program and Bank Secrecy Act requirements;
- provides training for appropriate personnel in detection of suspicious transactions; and
- provides for independent review to monitor and maintain an adequate program.
In addition to the closure of his business, Saleh Adam agreed to immediately “cease engaging directly or indirectly in conduct and transactional activities related to money transmission, as well as any other money services that require registration with FinCEN,” the agency said.
Julie DiMauro is the executive editor of FCPA Blog and can be reached here.