On March 11, 2016, the Financial Crimes Enforcement Network (FinCEN) issued guidance to Money Services Businesses (MSBs) to reiterate “the existing anti-money laundering (AML) program requirements on the principals of MSBs to understand and appropriately account for the risks associated with their agents.” The current guidance (FIN2016-G001) specifically references guidance issued by FinCEN in 2004 (See Interpretive Release 2004-1 from FinCEN), which focused on foreign agents and counterparty risks. The guidance is intended to clarify AML program requirements in light of state-specific issuances related to MSB principal-agent relationships and provide MSBs and their agents an understanding of how to comply.

The Guidance can be found at: https://www.fincen.gov/statutes_regs/guidance/pdf/FIN-2016-G001.pdf.