Comment from Money Services Business Association (MSBA)
Money Services Business AssociationSupportAdvocacy
Summary: The Money Services Business Association (MSBA) supports the proposed modernization of AML/CFT programs, particularly the shift toward an outcomes-based "effectiveness" standard. However, they urge FinCEN to ensure the final rule includes flexibility for the MSB agent model, proportionate requirements for small businesses, and a lengthy implementation period of 18 to 24 months.
The Money Services Business Association ("MSBA") respectfully submits our comments. MSBA is the largest national trade association representing licensed money services businesses.