Money services business penalized for repeated AML deficiencies
Wednesday, July 16, 2014 at 7:08AM
Julie DiMauro in AML, Bank Secrecy Act, FinCEN, Internal Revenue Service’s Small Business/Self-Employed Division, Jennifer Shasky Calvery, Mian Inc., currency transaction report, money services business

The Financial Crimes Enforcement Network (FinCEN) announced Tuesday its assessment of a civil penalty against Georgia-based Mian, Inc. for violating the Bank Secrecy Act’s program and reporting requirements.

Mian, a money services business (MSB), committed numerous violations even after being put on notice by the Internal Revenue Service’s that it had deficiencies in meeting its reporting obligations.

The BSA requires MSBs to implement an effective, written anti-money laundering (AML) program, which Mian failed to do.

Mian also provided check-cashing services without fulfilling its obligations to report and maintain records on relevant transactions.

The company's inadequate AML procedures did not ensure the timely and accurate filing of currency transaction reports (CTRs), which it was required to file within 15 days of any currency transaction exceeding $10,000.

From December 2010 through November 2011, Mian failed to file CTRs on approximately 40 percent of transactions that required filing. During this time, the CTRs that Mian actually filed were late and inaccurate. 

"There is no excuse for repeated violations of the BSA, especially after notification of the violations by examiners," said FinCEN Director Jennifer Shasky Calvery. "MSBs have an important role in implementing procedures to thwart serious illicit activity that could jeopardize the U.S. financial system. Those that follow the rules should welcome the fact that there are consequences for those that don’t."

Mian admitted that it violated the BSA's program, reporting and registration requirements, and it consented to a civil money penalty of $45,000. 

FinCEN's news release about the civil money penalty against Mian, Inc. can be found here.


Julie DiMauro is the executive editor of FCPA Blog and can be reached here.

Article originally appeared on The FCPA Blog (
See website for complete article licensing information.