Which action is explicitly listed as a typical AML requirement for MSBs?

• A. Register with FinCEN
• B. Obtain a banking charter
• C. Publish annual AML reports
• D. Submit quarterly audits

Answer: (A)

Registering with FinCEN is a fundamental AML requirement for MSBs because the Bank Secrecy Act designates FinCEN to oversee money services businesses and requires them to register. This creates a formal record, assigns an identifier, and signals regulators that the MSB has begun operations and will implement AML controls like a written program, a designated compliance officer, and ongoing monitoring. Without this registration, an MSB isn’t in the regulatory system that tracks and enforces AML obligations.

The other options don’t reflect standard AML duties for MSBs: obtaining a banking charter is for traditional banks that take deposits; publishing annual AML reports is not a typical public obligation for MSBs; and quarterly audits are not universally mandated AML requirements for MSBs, though some regulated contexts may require audits.