Silk Road forums
Discussion => Security => Topic started by: Winston420 on December 09, 2012, 08:50 pm
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For everyone that uses a money transmitter like moneygram for buying/selling bitcoins, you should be aware of the requirement for retailers that act as money transmitters that they can file a "Suspicious Activities Report" with the federal government, based on your behavior.
A PDF of this form, with the instructions, is here: http://www.fincen.gov/forms/files/fin109_sarmsb.pdf (warning: clearnet, on a federal site)
The thing is, it shouldn't be triggered unless you do over $2000 in transactions, but citizen narcs can be overzealous. Below is from the instructions in the form:
Notification Prohibited
Federal law (31 U.S.C. 5318(g)(2)) provides that
a financial institution, and its directors, officers,
employees, and agents, who report suspicious
transactions to the government voluntarily or as
required by 31 CFR 1022.320, may not notify
any person involved in the transaction that the
transaction has been reported.
Notification Required
In situations involving suspicious transactions
requiring immediate attention, such as ongoing
money laundering schemes, a money transmitter;
a currency dealer or exchanger; or an issuer, seller,
or redeemer of money orders and/or traveler’s
checks shall immediately notify, by telephone,
an appropriate law enforcement authority. In
addition, a timely SAR-MSB form shall be filed,
including recording any such notification in Part
VI on the form.
A. When To File A Report:
1. Money transmitters; currency dealers and
exchangers; and issuers, sellers and redeemers
of money orders and/or traveler’s checks that are
subject to the requirements of the Bank Secrecy
Act and its implementing regulations (31 CFR
Chapter X are required to file a suspicious
activity report (SAR-MSB) with respect to:
a. Any transaction conducted or attempted
by, at, or through a money services business
involving or aggregating funds or other assets of
at least $2,000 (except as described in section
“b” below) when the money services business
knows, suspects, or has reason to suspect that:
Catalog No. 35084Y
i. The transaction involves funds derived
from illegal activity or is intended or conducted
in order to hide or disguise funds or assets derived
from illegal activity (including, without limitation,
the nature, source, location, ownership or control
of such funds or assets) as part of a plan to violate
or evade any Federal law or regulation or to avoid
any transaction reporting requirement under
Federal law or regulation;
ii. The transaction is designed, whether
through structuring or other means, to evade any
regulations promulgated under the Bank Secrecy
Act; or
iii. The transaction has no business or
apparent lawful purpose and the money services
business knows of no reasonable explanation for
the transaction after examining the available facts,
including the background and possible purpose
of the transaction.
iv. The transaction involves the use of the
money services business to facilitate criminal
activity.