This is a brief read, but it goes to show, that FATF is starting to get serious about the derisking problem. Today, finding an MSB Friendly Bank is next to impossible. It has been a huge issue for many years now, but now it has gotten to the point of collapsing the industry on itself.
With the recent Western Union fiasco and the fines levied by FinCEN (nice income by the FinCEN!), MSBs are often complacent when it comes to their responsibility regarding Agent Monitoring. I thought I’d dig up the original rule book of the FinCEN guidance – and here it is.