Independent Review Form – Fill Out and Use This PDF

Please Complete ALL Parts, Questions, Blanks, and Fields

Note: The Independent Review cannot be conducted by your designated Compliance Officer, anyone that reports to your Compliance Officer, or any MoneyGram representative.

Part 1: MONEY SERVICES BUSINESS (MSB) REGISTRATION (Only Check One)

MSB Registration is NOT required at the time of this review because the Business DOES NOT conduct a money service business on its own behalf and is covered by the MoneyGram MSB Registration.

MSB Registration IS required at the time of this review because the Business DOES conduct a money service business on its own behalf and IS registered as a MSB with the US Department of Treasury. A copy of the registration IS kept in the Business AML Files.

Part 2: RISK ASSESSMENT

MSBs are often targeted by money launderers or other criminals to help them hide or disguise the nature, location, source, ownership or control of illegally obtained money. The risk of this occurring increases based on the location of the Business, the number and types of financial services offered and/or the number of providers offered. Offering multiple products and/or services increases a money launderer or other criminal's ability to structure transactions to avoid detection and recordkeeping requirements.

If more than one (1) product or service is offered, the Independent Reviewer should review the Business' Compliance Program with more in-depth analysis on each type of product or service offered.

Location Risk

Law enforcement agencies and government regulators have identified areas that are at higher risk for money laundering, related financial crimes, and drug and human trafficking. The appropriate websites are listed to help determine the correct response to the following questions:

Product Risk

Which products or services below does the Business offer: (Check all that apply)

Service Risk

Being an Agent for more than one MSB provider/competitor of money services makes it easier for a money launderer or other criminal to structure transactions to avoid detection and recordkeeping requirements.

If "Yes", please list all Business' MSB Providers:

Compliance Officer

Briefly describe, in the space below, the responsibilities of the Compliance Officer and explain how the Independent Reviewer is certain the Compliance Officer understands and complete the responsibilities of this position:

Compliance Program

Briefly describe, in the space below, how the Compliance Program was verified by the reviewer:

Briefly describe, in the space below, how these limits are monitored and enforced:

Yes No

Yes No

Yes No

Yes No

Yes No

Yes No

Yes No

If a "No" was checked for any question above, please use the space below to explain why:

Training Frequency Schedule

Please indicate below the schedule the Business implements for employee AML Compliance related training: (Check all that apply)

Briefly describe, in the space below, the training material and content:

Briefly describe, in the space below, how the employee training process/content was verified by the reviewer:

Customer Identification

Briefly describe, in the space below, how the customer I.D. process was verified by the reviewer:

Money Order Processing

How often are money order logs reviewed to determine if CTRs and/or SARs should have been E-Filed?

Money Transfers Processing

Yes No Are money transfer send/receive forms or form free receipts accurately completed for transfers of $3,000 or more?

How often are money transfer send/receive forms or form free receipts reviewed to determine if CTRs and/or SARs should have been E-Filed?

Briefly describe, in the space below, how the money order/transfer processes was verified by the reviewer:

If a "No" or "Other" was checked for any question above, please use the space below to explain why:

E-Filing Suspicious Activity Reports (SARs)

Transaction activity is reviewed:

E-Filing Currency Transaction Reports (CTRs)

Yes No Does the Compliance Officer (or their designee) review all transaction activity to identify those transactions that, either individually or combined, may require a CTR to be E-Filed?

Transaction activity is reviewed:

Briefly describe, in the space below, how the SAR/CTR E-File processes was verified by the reviewer:

If a "No" or "Other" was checked for any question above, please use the space below to explain why:

Yes No

Yes No

Yes No

Yes No

Briefly describe, in the space below, how the Dodd-Frank processes was verified by the reviewer:

If a "No" was checked for any question above, please use the space below to explain why:

Part 8: INDEPENDENT REVIEW

Yes No Are Independent Reviews regularly conducted on the Business to monitor and maintain a required compliance program?

How often is an Independent Review conducted?

Briefly describe, in the space below, how the Independent Review process was verified by the reviewer:

If a "No" or "Other" was checked for any question above, please use the space below to explain why:

Yes No

Briefly describe, in the space below, the results of the business data and records analysis:

Business Data and Records Analysis Guidelines

1.Money transfers of $900 and above must include the customer's:

Name

Current residential address

Phone number

Type of ID provided, the ID number and the ID issuer

2.Money transfers of $3,000 and above must include the customer's:

Name

Current residential address

Phone number

Type of ID provided, the ID number and the ID issuer

Social Security number (SSN) or Tax ID Number (TIN), if the customer is a citizen or authorized resident in the U.S. A SSN or TIN is unnecessary if the customer lives and works outside of the U.S. and presents a passport or other applicable photo ID issued by a foreign government.

Date of birth (DOB)

Specific occupation

Signature

3.Multiple money order cash purchases made by the same person in one business day must be aggregated, or added together, and treated as a single purchase, even if purchased at different times during the day. If the same consumer purchases $3,000 or more in money orders, using cash, in the same day, the following consumer transaction information must be recorded on a Money Order Log BEFORE completing the transaction(s):

Name

Current residential address

Phone number

Type of ID provided, the ID number and the ID issuer

Social Security number (SSN) or Tax ID Number (TIN), if the customer is a citizen or authorized resident in the U.S. A SSN or TIN is unnecessary if the customer lives and works outside of the U.S. and presents a passport or other applicable photo ID issued by a foreign government.

Date of birth (DOB)

Specific occupation

Signature

4.Aggregated transaction activity should be reviewed to determine if SARs or CTRs were required to be E-Filed.

Business Name/Business DBA:

Business Street Address:

City: State: Zip:

Business Name/Business DBA:

Business Street Address:

If additional locations blanks are needed, please copy this page and add accordingly.