AML/CFT for MSBs and Payment Institutions

Anti-Money Laundering AML/CFT October 25, 2025
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Introduction

This specialized course provides comprehensive training on AML/CFT requirements and implementation for money service businesses (MSBs) and payment institutions. Participants will learn about the unique risks associated with money transmission, currency exchange, and payment services, along with specific regulatory expectations for these sectors. The course covers risk assessment, customer due diligence, transaction monitoring, and compliance program development tailored to MSB and payment institution operations. Through practical case studies and sector-specific exercises, learners will develop the expertise needed to implement effective AML/CFT programs.

Objectives

Key Learning Objectives:

  • Understand AML/CFT obligations for MSBs and payment institutions
  • Learn sector-specific risks and vulnerabilities
  • Master customer due diligence requirements for money transmission
  • Develop skills in transaction monitoring and reporting
  • Learn to conduct risk assessments for MSB operations
  • Understand regulatory expectations for MSB compliance programs
  • Master agent management and oversight requirements
  • Learn to implement effective controls for digital payments
  • Develop compliance program implementation strategies

Target Audience

  • MSB owners and operators
  • Payment institution compliance staff
  • Money transmission agents
  • Fintech and digital payment providers
  • Regulatory supervisors of MSBs
  • AML/CFT consultants
  • Legal advisors to payment services
  • Risk management professionals

Methodology

  • MSB-specific case studies
  • Risk assessment workshops
  • Transaction monitoring exercises
  • CDD documentation practice
  • Agent management role-playing
  • Regulatory requirement analysis
  • Industry expert presentations

Personal Impact

  • Enhanced understanding of MSB obligations
  • Improved risk assessment and monitoring skills
  • Stronger compliance program development capabilities
  • Better agent management and oversight abilities
  • Increased confidence in MSB compliance
  • Career development in payment services compliance

Organizational Impact

  • Reduced regulatory compliance risks
  • Enhanced operational compliance
  • More effective risk management
  • Improved regulatory relationships
  • Stronger agent network controls
  • Better preparation for regulatory examinations

Course Outline

Unit 1: MSB Regulatory Framework

Legal Obligations
  • MSB definition and registration requirements
  • Federal and state regulatory frameworks
  • Payment institution licensing
  • Enforcement actions and penalties
Sector Overview
  • Money transmission risks
  • Currency exchange operations
  • Payment instrument issuance
  • Digital payment platforms

Unit 2: Risk Assessment and Management

Sector-Specific Risks
  • Product and service risk analysis
  • Geographic risk assessment
  • Channel and delivery method risks
  • Agent network vulnerabilities
Risk Mitigation
  • Transaction limit setting
  • Customer risk categorization
  • Agent oversight controls
  • Monitoring system configuration

Unit 3: Customer Due Diligence

Identification Requirements
  • Customer identification program
  • Transaction threshold monitoring
  • Enhanced due diligence triggers
  • Ongoing customer verification
Sector-Specific CDD
  • MSB customer risk assessment
  • Non-face-to-face verification
  • Agent performed CDD
  • Digital identity validation

Unit 4: Transaction Monitoring and Reporting

Detection Systems
  • MSB-specific red flags
  • Structuring and smurfing detection
  • Transaction pattern analysis
  • Real-time monitoring capabilities
Reporting Obligations
  • Currency transaction reports
  • Suspicious activity reporting
  • Funds transfer requirements
  • Record-keeping standards

Unit 5: Compliance Program Implementation

Program Development
  • Policies and procedures creation
  • Compliance officer appointment
  • Training and awareness programs
  • Independent testing requirements
Operational Management
  • Agent management and oversight
  • Technology system implementation
  • Management reporting
  • Regulatory examination preparation

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