Washington State Department of Financial Institutions

Money Transmitters Examination FAQs

Answers to common questions about examinations conducted by DFI.

Where can I find a copy of the Department of Treasury’s Specially Designated Nationals (SDN) list?

A copy of the most recent list can be found on the Office of Foreign Assets Control (OFAC) Web site. From this site you can also sign-up to receive e-mail updates when any information changes on the SDN list.

What are the regulatory requirements regarding conducting an independent review of our Anti-Money Laundering (AML) Program?

The Financial Crimes Enforcement Network (FinCEN) under the Department of the Treasury has issued guidance to help money services businesses understand the requirements of an independent review. View the Guidance (PDF)*

As a money transmitter, I am required to have audited annual financial statements. Where can I verify if my accountant is certified and/or find a certified accountant to provide this service?

The American Institute of Certified Public Accountants provides a link to every individual State Board of Accountancy where you can go to search for a specific individual or firm in order to verify certification. Visit the AICPA Web site.

What is a “risk assessment”? And am I required to have one?

A BSA/AML risk assessment evaluates all risk areas of the company, including areas such as products, services, customers, entities, volume, and geographic locations. The provisions of the Bank Secrecy Act do not require a risk assessment in writing. However, the risks associated with a company must be evaluated to ensure an adequate anti-money laundering program is in place to prevent money laundering and/or terrorist financing.

What financial records am I required to keep?

Money transmitter licensees are required to keep a general ledger (posted at least monthly), bank reconciliations (preferably conducted monthly), and annual audited financial statements. In order to prove compliance, licensees should also maintain a database of all transactions conducted, and records proving.

What should I expect on an examination?

DFI conducts examinations of its money transmitter licensees approximately every 6-24 months, depending on the risk posed by the business. On an examination, licensees undergo an in-depth financial analysis, where asset quality, capital adequacy, earnings performance, net worth, liquidity, and permissible investments are evaluated. In addition, the examiner will review the licensee’s transactions to ensure compliance with federal recordkeeping and reporting requirements. Management will be assessed to ensure they are not running the company in a manner that could prove to be unsafe for Washington consumers. The examiner will also review compliance with various other parts of the Uniform Money Services Act, as well as other applicable state and federal laws. The onsite examination can take anywhere from three days to several weeks, depending on the complexity of the licensee’s operations, willingness to provide requested documentation, and overall level of compliance.

* This document is a PDF file, and you will need Adobe Acrobat Reader to view it. If you don't already have Acrobat Reader installed on your computer, you may download it for free from Adobe.