Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice regarding the release of the new electronic Registration of Money Services Business, FinCEN Report 107. The new report will fully replace the most recent FinCEN Report 107 and facilitates registration for all money services businesses (“MSBs”) electronically, including foreign-located MSBs and providers of prepaid access. The new FinCEN Report 107 is only available electronically.
The previous FinCEN Report 107 did not accommodate electronic filings by foreign-located MSBs and providers of prepaid access. Accordingly, with the availability of the new FinCEN Report 107, foreign-located MSBs and providers of prepaid access must file the new report electronically within the compliance deadlines previously issued by FinCEN (January 23, 2012, for foreign-located MSBs and March 31, 2012, for providers of prepaid access). All other MSBs may continue to file the previous FinCEN Form 107 as required by FinCEN until March 31, 2013.
As a result of the foregoing, financial institutions may find it necessary to update their KYC/CDD programs if they provide financial services to MSBs (including, foreign located MSBs and providers of prepaid access) to assess whether such customers are duly registered with FinCEN and not engaged in unlicensed MSB activity.
Read the original notice.
Authors: Clemente Vazquez-Bello, Andres A. Fernandez and Gabriel Caballero
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