Remittances: How are AML/KYC responsibilities divided for online transfers from the U.S. to foreign countries?
Cross-Border Payments
Asked by Question Bot04/Oct/20141 answer
1 Answer
F
Faisal Khan
Answered 04/Oct/2014
AML-KYC is the responsibility of both the parties.
From the US (Remitting side) your US based MSB is responsible for doing the AML and KYC checks (amongst others, think: OFAC, SAR, CTR, etc.)
On the receiving side (Beneficiary country) you would be responsible for doing the AML/KYC checks based on your own country's laws as laid out by your financial regulator.
Ideally, both transactions should do a swap check as well, to ensure the money transfer transaction does not have to be reversed unnecessarily.
This means:
Remitting Side
Will do a check on the Sender as well as the Beneficiary
Receiving Side
Will do a check on the Sender as well as the Beneficiary
Both these checks should happen prior to the transaction being executed.
From the US (Remitting side) your US based MSB is responsible for doing the AML and KYC checks (amongst others, think: OFAC, SAR, CTR, etc.)
On the receiving side (Beneficiary country) you would be responsible for doing the AML/KYC checks based on your own country's laws as laid out by your financial regulator.
Ideally, both transactions should do a swap check as well, to ensure the money transfer transaction does not have to be reversed unnecessarily.
This means:
Remitting Side
Will do a check on the Sender as well as the Beneficiary
Receiving Side
Will do a check on the Sender as well as the Beneficiary
Both these checks should happen prior to the transaction being executed.