Form Cm 0011 – Fill Out and Use This PDF

The CM-0011 form serves as a critical tool in combating money laundering within the check-cashing industry. It mandates a separate independent review for each physical location, to be completed by the company’s designated Anti-Money Laundering (AML) Compliance Officer, Manager, or Owner. This form underscores the importance of adhering to the Bank Secrecy Act/Anti-Money Laundering compliance program and facilitates the submission of pertinent documents for review. If you need to fulfill your compliance obligations, click the button below to start filling out your form.

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Form Cm 0011 PDF Details

In an era where financial transactions are scrutinized for integrity, the CM-0011 form emerges as a critical tool in the fight against money laundering within the check-cashing sector. Designed to enforce stringent adherence to the Bank Secrecy Act and Anti-Money Laundering (AML) compliance programs, this form mandates an independent review for each location operated by check-cashing businesses. To complete it, companies must lean on their designated AML compliance officers, managers, or owners to provide comprehensive details about their operations. Among the required information are business identifiers, the scope of financial services offered, employee details including background checks, and documentation of BSA/AML training. It calls for transparency about the operational days, transaction and customer verification processes, and how the business handles large transactions and reports suspicious activities. Further amplifying its importance, the form also probes into how these establishments ensure compliance with state and federal examinations, and maintain accurate records for audits. By demanding a thorough walkthrough of a business’s compliance framework and operational practices, the CM-0011 form serves an indispensable role in certifying that check-cashing entities are not conduits for money laundering but are instead responsible participants in the global financial system.

Question	Answer
Form Name	Form Cm 0011
Form Length	8 pages
Fillable?	No
Fillable fields	0
Avg. time to fill out	2 min
Other names	independent review template, independent review form, anti money laundering program for check cashing, fincen msb independent review form

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CHECK CASHING

ANTI-MONEY LAUNDERING INDEPENDENT REVIEW

A SEPARATE INDEPENDENT REVIEW FORM WILL BE REQUIRED FOR EACH PHYSICAL LOCATION AND IS TO BE COMPLETED BY THE COMPANY’S DESIGNATED AML COMPLIANCE OFFICER, MANAGER, OR OWNER. PLEASE ATTACH A COPY OF YOUR MOST CURRENT WRITTEN BANK SECRECY ACT/ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM AS WELL AS ALL DOCUMENTS AS INDICATED BELOW. SUBMIT THIS COMPLETED FORM AND REQUESTED INFORMATION TO THE BSA DEPARTMENT OF MBOC. ALL INFORMATION WILL BE REVIEWED AND WRITTEN RESULTS AND RECOMMENDATIONS WILL BE FORWARDED BACK TO THE COMPANY’S AML DESIGNATED COMPLIANCE OFFICER. REFER TO MASTER SERVICE AGREEMENT WITH MBOC PERTAINING TO THE BANK’S USE OF THE INFORMATION BEING REQUESTED AND THE REQUIREMENT OF THE BANK’S CUSTOMER TO COMPLY.

Business/Owner’s Name:

Business DBA/Trade Name:

Number of years in Business for this Location: Number of Additional Locations:

Location Address:

What days of the week is this business location open?

Monday

Tuesday

Wednesday

Thursday

Friday

Saturday

Sunday

What are the business hours?

Name of BSA Compliance Officer:

Number of years Compliance Officer has been working for Business:

1.What types of financial services is provided at this location:

Receive Money Remittance

Send Money Remittance

Sell Money Orders

Check Cashing Currency Exchanges Sell Traveler’s checks

Sell Prepaid Debit/Phone Cards

Electronic Bill Pay

Payday Lending

2.What other types of businesses are conducted at this location (grocery, liquor sales, insurance, tax preparation, etc.):

______________________________________________________________________

3.How many employees are at this location? __________

4.Are there files for each employee, which include criminal background checks?

Yes

No.

a.If “No” write down the reason(s) why there are no documented employee files/what is the hiring process:

___________________________________________________________________

5.Does the business have a fee schedule posted for MSB services? a. If “No” indicate the reason why not:

Yes

___________________________________________________________________

CM-0011 (Rev. 06/13) PC

Page 1 of 8

CHECK CASHING

ANTI-MONEY LAUNDERING INDEPENDENT REVIEW

Business/Owner’s Name:

Business DBA/Trade Name:

Location Address:

6.Has BSA/AML training been completed for all appropriate employees including the Compliance Officer within the last 12

months? Yes No

a.If “Yes” provide copies of all current BSA/AML training logs and training material

b.If “No” provide written explanation as to why no current BSA/AML training was performed for all appropriate employees or why copies of all current BSA/AML training logs and training material is not available.

___________________________________________________________________

7.Has this location been examined by State/IRS Examiners?

Yes

No (skip to question 8).

a. If “Yes” date of last State/IRS Examination: _________________ (attach copy of results)

b.If “Yes”, were all recommendations completed?

Yes

No.

If “No” indicate the reason(s) why each recommendation was not completed

___________________________________________________________________

8.Has this location been examined within the last 12 months by all of the Business’ MSB Principal(s) for agent services?

Attach copies of the MSB Principal(s) AML independent review forms.

Yes

N/A

a.If “Yes”, were all recommendations completed?

Yes

No.

b.If the answer to questions 6 or 6a. are “No” indicate the date the last independent AML review was completed by each MSB Principal- include the name of the MSB Principal and or why previous or current recommendations were not completed.

___________________________________________________________________

CM-0011 (Rev. 06/13) PC

Page 2 of 8

CHECK CASHING

ANTI-MONEY LAUNDERING INDEPENDENT REVIEW

Business/Owner’s Name:

Business DBA/Trade Name:

Location Address:

9.How do you know that employees have accounted for all cash and that the cash/checks are either deposited into the bank or kept in the safe? Indicate where in the business’ BSA/AML Compliance Program this information is located or describe in writing the controls in place, if a formal written process is not available.

______________________________________________________________________

10.What is this location’s system in determining if a transaction that meets BSA filing requirements is detected (e.g., how you would find more than one transaction conducted by a single person in a 24 hour period)?

______________________________________________________________________

11.What is this location’s process to prevent a customer from making transactions for someone, no one knows, or for other customers?

______________________________________________________________________

CM-0011 (Rev. 06/13) PC

Page 3 of 8

CHECK CASHING

ANTI-MONEY LAUNDERING INDEPENDENT REVIEW

Business/Owner’s Name:

Business DBA/Trade Name:

Location Address:

12. What is this location’s process for reporting suspicious activities (only check cashing is not required to file SAR-MSBs)?

______________________________________________________________________

13. Does this location conduct transactions for customers who do not live or work locally (within city limits of business

location)?

Yes

a.If “Yes” provide written explanation as to who these customers are and why this location offers services to customers that do not live/work in the area:

___________________________________________________________________

14. Does this location cash checks for customers who do not have ID?

Yes

a.If “Yes” is there, any restrictions on what type of check can be cashed. Describe internal controls

b.If “No”, what type of ID is required to cash a check for the first time at this location?

___________________________________________________________________

15.Does this location cash checks for any person who is not the named payee on the checks? a. If “Yes”, indicate the reason in detail:

Yes

___________________________________________________________________

CM-0011 (Rev. 06/13) PC

Page 4 of 8

CHECK CASHING

ANTI-MONEY LAUNDERING INDEPENDENT REVIEW

Business/Owner’s Name:

Business DBA/Trade Name:

Location Address:

16. How are ID records kept (digitally, scanned, paper copy), where are they stored and how long before destroyed?

______________________________________________________________________

17. How do you ensure that all the required ID records are complete for each new customer?

______________________________________________________________________

18. ID’s expire so what is this location’s process to verify the ID of a regular customer?

______________________________________________________________________

19. What is this location’s process for handling a check that is over $10,000 (Currency Transaction Reporting)?

______________________________________________________________________

CM-0011 (Rev. 06/13) PC

Page 5 of 8

CHECK CASHING

ANTI-MONEY LAUNDERING INDEPENDENT REVIEW

Business/Owner’s Name:

Business DBA/Trade Name:

Location Address:

20.Does this location temporarily hold funds for customers that are not recorded in the records? a. If “Yes”, indicate the reason and who the customers are in detail:

Yes

___________________________________________________________________

21.Does this location make payments on behalf of your customers (outside of agent services)? a. If “Yes”, indicate the reason in detail and if this is regular transactions:

Yes No

___________________________________________________________________

22. Does this location accept checks/negotiable instruments from other MSBs or have ever loaned another MSB currency or other funds or borrowed from another MSB? Yes No

a.If “Yes”, indicate the reason in detail and if this is regular transactions:

___________________________________________________________________

23.Does this location deposit all the cashed checks from the day’s sales into the bank on the same day? a. If “No”, indicate the reason in detail:

Yes No

___________________________________________________________________

CM-0011 (Rev. 06/13) PC

Page 6 of 8

CHECK CASHING

ANTI-MONEY LAUNDERING INDEPENDENT REVIEW

Business/Owner’s Name:

Business DBA/Trade Name:

Location Address:

24.Does this location physically transport currency or monetary instruments into or out of the United States?

Yes No

a.If “Yes”, How is the currency transported, who are your customers, what are your fees, how do you record these transactions and please provide confirmations that CMIR reports have been filed:

___________________________________________________________________

25.Does this location mail or take currency or monetary instruments from customers/sources outside the United States?

Yes No

b.If “Yes”, Who are your customers, what are your fees, how do you record these transactions and please provide confirmations that CMIR reports have been filed:

___________________________________________________________________

CM-0011 (Rev. 06/13) PC

Page 7 of 8

CHECK CASHING

ANTI-MONEY LAUNDERING INDEPENDENT REVIEW

CERTIFICATION

I CERTIFY, UNDER PENALTY OF PERJURY, UNDER ANY AND ALL APPLICABLE FEDERAL AND STATE LAWS, THAT: The undersigned represent(s) that all statements contained in this form and in the other documentation pertaining to business name and address listed below which are being submitted in support of this form are true and correct. The person signing this form further represents that s/he is authorized to make the above representations, and if applicable, is an authorized representative of named business.

Business/Owner’s Name:

Business DBA/Trade Name:

Location Address:

_________________________________________________________________

Signature of the AML Compliance Officer/Owner/Manager

_________________________________________________________

Printed Name

_________________________________________________________

Full Title/Position in Company

________________________________

Date Completed

CM-0011 (Rev. 06/13) PC

Page 8 of 8

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Has this location been examined, Yes, and If the answer to questions or a inside independent review form

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Form Cm 0011 – Fill Out and Use This PDF

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