A $3,000 transfer out of two Minnesota counties will carry the recipient's date of birth, telephone number and email address to FinCEN
Three thousand dollars. That is the point at which a transfer leaving Hennepin or Ramsey County starts generating a file in Washington.
The Financial Crimes Enforcement Network renewed its Minnesota geographic targeting order on Friday. It takes effect on 11 August and ends on 6 February, which is the full 180 days the statute allows for an order of this kind. It reaches any bank or money transmitter with a branch, subsidiary or office in the two counties, and it reaches funds transfers of $3,000 or more where the originator gives an address inside the covered area and the money is heading to a beneficiary, a recipient, or a receiving institution outside the United States.
Two categories of sender are carved out. Companies traded on an exchange the Securities and Exchange Commission regulates, and financial institutions that already run anti-money laundering programmes under the Bank Secrecy Act.
What the report has to carry
The list is longer than a wire record.
A bank reports everything section 1020.410(a) already makes it keep, and then the beneficiary's name, address, date of birth, telephone number, email address and account number. It also answers whether the money came from a federal, state or local government contract or benefit programme, and if it did, whether those payments went from a government agency to an entity the originator holds an ownership interest in.
A money transmitter answers a longer version of the same list about the recipient, plus how the transmittal was funded, whether by currency, cheque, card or something else, and what form it took, meaning a wire, a convertible virtual currency transmission, a ledger entry, or other. Then comes the last question. If the transmittal is a ledger entry tracking credits and debits with hawaladars located internationally, the transmitter has to say whether it uses cash couriers to settle those debits.
Reports go through FinCEN's Financial Industry Portal as a CSV file, filed under the file type Special Measures with the code FIN-65547-X3M6T, by the end of the month after the month in which the transaction took place. Records are kept for five years from the last day the order is in force.
Why Minnesota
Treasury says why. Its announcement says schemes have fraudulently diverted state and federal money meant for people who lack housing, are food insecure or have disabilities, that the cost to Minnesota is potentially in the billions, and that a portion of it has been laundered overseas. The order itself is briefer: the action is taken in furtherance of Treasury's efforts to combat international money laundering relating to government benefits fraud in Minnesota. Nobody is named in either document.
This is a renewal, not a new instrument. Treasury says the reporting requirements are unchanged from the February order, and that an exemption issued on 27 February, releasing a subset of banks from recording or reporting transfers where the originator falls into certain categories, has been folded into the renewed text.
The order is signed by Jimmy L. Kirby, the deputy director. Willful violation of any term carries civil or criminal penalties, and a covered business has to pass the order to every agent it has in the two counties and to its chief executive.
