Meta Payment Systems. Anti-Money Laundering Agent Handbook

Transcription

1 Meta Payment Systems Anti-Money Laundering Agent Handbook

2 To Our Valued Agent Network As an agent of Meta Payment Systems (MPS), you are part of a national group of companies that have joined with MPS and IPP of America Inc. (IPP) to offer electronic bill payment services to consumers. Under the Bank Secrecy Act (BSA), as amended by the USA PATRIOT Act, all providers of financial services are required to develop and implement Anti-Money Laundering (AML) Compliance Programs. As the sponsoring financial institution, MPS is committed to full satisfaction of the requirements of the BSA and has created an AML Compliance Program designed to achieve that goal. It is critical to the success of our AML compliance efforts that each payment center (agent) adopt and implement an AML Compliance Program that integrates with MPS AML Compliance Program to provide a consistent AML function across our agent network. As our agent, you have an independent obligation to develop and implement your own AML Compliance Program if you are a Money Services Business (MSB) or agent of a MSB. Because of MPS ongoing commitment to providing our agents with robust support materials, and because the concept of an AML Compliance Program may be new to some of our agents, MPS has prepared this handbook as a guide and resource for you. Your company or business may already have an AML Compliance Program that covers other financial services, such as providing money transfers, check cashing, or selling money orders. If this is the case, this handbook can be used as an additional resource to help assure that your program is complete. This handbook is not intended to provide legal advice. Rather, it is intended to help you build an AML Compliance Program to support your company s compliance operations and discourage individuals from using your business to promote illegal activities. As always, we encourage all agents to consult with their own legal counsel for specific guidance regarding their AML compliance obligations. Thank you for your commitment. Jani Gode, C.A.M.S. Assistant Vice President BSA/AML and OFAC Officer Meta Payment Systems MetaBank Meta Financial Group, Inc Meta Payment Systems. All Rights Reserved

3 Table of Contents Icons and Summary of Terms The Basics of Money Laundering... 1 The Basics of Terrorist Financing... 2 Requirements of an Anti-Money Laundering Compliance Program... 2 Designation of a Compliance Officer... 3 Internal Controls... 3 Training Program... 4 Independent Review... 4 Knowing Your Customers... 5 Requirements of your Customer Identification Program... 5 Customer Notification... 5 Collection of Required Customer Information... 5 Verification of Customer Identity... 6 Comparison to Government Lists - OFAC... 6 CIP Recordkeeping... 6 Unusual or Suspicious Activity... 6 Reporting Suspicious Activity Transaction Report... 7 Confidentiality... 7 Recordkeeping... 8 Safe Harbor... 8 Currency Transaction Reporting... 8 Aggregation... 9 Recordkeeping... 9 Summary of To Do Items Contact Information Meta Payment Systems. All Rights Reserved

4 Icons Examples Frequently Asked Questions To Be Completed and Sent to MPS or IPP Summary of Terms MPS = Meta Payment Systems A division of MetaBank and the provider of the electronic bill payment service you are offering. BSA = Bank Secrecy Act U.S. government legislation that was created in 1970 to prevent financial businesses from being used as tools by criminals to hide or transfer money derived from their illegal activity. This is achieved by requiring financial institutions to report cash transactions in excess of $10,000 and provide documentation on suspicious activity. AML = Anti-Money Laundering Legal controls that require financial institutions and other regulated businesses to prevent or report money laundering activities. USA PATRIOT Act = Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 An act of Congress, signed into law in 2001 after the September 11 th attacks, which targets terrorism and those who finance terrorism; and amends the Back Secrecy Act. MSB = Money Services Business A business is classified as an MSB if it offers money orders, traveler s checks, check cashing, currency dealing or exchange, and/or stored value AND conducts more than $1,000 in money services business activity with the same person (in one type of activity) on the same day OR provides money transfer services in any amount. HIDTA = High Intensity Drug Trafficking Area HIFCA = High Risk Money Laundering and Related Financial Crimes Areas Certain parts of the United States that have been jointly designated by the U.S. Treasury and Justice departments as high intensity for drug trafficking and/or high risk for financial crimes. CIP = Customer Identification Program A company s formal customer identification and verification policies and procedures Meta Payment Systems. All Rights Reserved

5 SAR = Suspicious Activity Report Required by the Bank Secrecy Act, a confidential form used to report suspicious activity and known or suspected violations of law. Used by law enforcement for investigations of money laundering, terrorist financing, or other criminal cases. CTR = Currency Transaction Report Initiated by the Bank Secrecy Act, a form that financial businesses are required to file for any currency transactions of more than $10,000 made in any one day by any person or made on behalf of another person. (not a confidential document) OFAC = Office of Foreign Assets Control A department of the U.S. Treasury that enforces economic and trade sanctions against countries and groups of individuals involved in terrorism, narcotics and other disreputable activities. SDN list = Specially Designated Nationals and Blocked Entities list A publication of the Office of Foreign Assets Control, which lists individuals and organizations whose properties are blocked by the Office's various sanctions programs which it administers. FinCEN = Financial Crimes Enforcement Network A bureau of the U.S. Department of the Treasury that collects and analyzes information about financial transactions in order to combat money laundering, terrorist financiers, and other financial crimes Meta Payment Systems. All Rights Reserved

6 The Basics of Money Laundering Money laundering is the attempt to conceal or disguise the nature, location, source, ownership, or control of illegally obtained money. Money laundering involves disguising financial assets so they can be used without detection of the illegal activity that produces them. Through money laundering, the criminal transforms the monetary proceeds derived from criminal activity into funds with an apparently legal source (turns dirty money into seemingly clean money). Money is laundered to conceal illegal activity, and the end result is that illegally-gained money is being introduced into the nation s legitimate financial systems. Money laundering is usually associated with drug trafficking, armed robbery, tax evasion, smuggling, prostitution, arms dealing, fraud, forgery, counterfeiting, bribery and corruption. Money laundering involves a series of complex transactions that include the following three steps: 1. Placement Placement is the initial introduction of the illegal proceeds into the financial system, and the most vulnerable step in the washing cycle for criminals. Many money launderers are familiar with the dollar thresholds that require recordkeeping and reporting. Therefore, in order to remain anonymous and avoid the detection of law enforcement agents, they will structure their transactions so that the recordkeeping or reporting requirements will not be triggered. Structuring is the act of breaking up a potentially large transaction into several smaller ones. Smurfing occurs when a large sum of money is distributed to several people who place the funds into the financial services system. Example of structuring: A customer wants to pay bills totaling more than $2,000, so the clerk asks to see identification for completion of the Transaction Report. The customer then says he/she doesn t want to pay all the bills, and instead pays half of the amount and returns the next day to pay the rest (in order to avoid showing identification and avoid reporting). Example of smurfing: Maria wants to quickly get rid of illegally-gained cash, so she asks several people to make bill payments on her behalf at many different payment locations. 2. Layering Moving funds around, which creates complex layers of financial transactions to confuse the audit trail, as well as disguise the source and ownership of funds. Example: John makes many payments to various credit card accounts within a 5-day period, at different payment centers. 3. Integration The final stage involves placing the now clean proceeds back into the economy to create the perception of legitimacy. This may include the purchase of automobiles, businesses, real estate, etc Meta Payment Systems. All Rights Reserved 1

7 The Basics of Terrorist Financing Terrorist financing differs from money laundering in that most funds are used for a purpose, rather than to conceal profits of a crime. Many times terrorist funds are not derived from illegal means. One instance where a terrorist funding scheme differs from a traditional money laundering scheme is the use of charitable funds for terrorist purposes. Generally, terrorist financing will use the same methods described under money laundering in order to move money and maintain the secrecy of transactions and access to funds. For the purposes of this handbook, AML is used to refer to both anti-money laundering and anti-terrorist financing. Requirements of an Anti-Money Laundering Compliance Program Under the BSA, as amended by the USA PATRIOT Act, all providers of financial services are required to develop and implement an AML compliance program. As our agent, you are required by the BSA and USA PATRIOT Act to adopt and implement an AML compliance program in order to offer our bill payment service. If you are a Money Services Business (MSB) or an agent of another MSB, you have an independent obligation to develop an AML program for the sale or service of your other products. Risk Assessment The first step in developing an adequate AML compliance program is to assess the risk inherent in your business, including the products and services you support and your geographic location. For example, some financial services are more attractive to money launderers than others. Also, some geographic locations are considered high risk areas for money launderers (i.e. High Intensity Drug Trafficking Area, HIDTA or High Risk Money Laundering and Related Financial Crimes Areas, HIFCA). Once you ve identified your risks, you will be able to better identify appropriate procedures to mitigate the risk. Your AML Compliance Program Your comprehensive AML program must be in writing and must include the following elements: Designation of a compliance officer responsible for daily compliance with the BSA and your AML Program Written policies, procedures and internal controls reasonably designed to assure compliance with the BSA Training program for employees Independent review of your AML program 2008 Meta Payment Systems. All Rights Reserved 2

8 Designation of a Compliance Officer Your Compliance Officer should be designated by your senior management or Board of Directors. While the Compliance Officer may have other duties at your company, he or she should be someone in a position of responsibility, and should be given the resources to accomplish the AML compliance responsibilities. Your Compliance Officer is responsible for: Ensuring day to day compliance with corporate policies and procedures contained in your AML program. Overseeing or managing the reporting process to ensure that all reports and all records are maintained in compliance with federal and state requirements. Monitoring changes in your business and the laws, regulations, and industry best practices to ensure that your AML program remains updated as necessary and reflects current industry standards. Developing and implementing a training program to ensure that your employees receive appropriate training with regard to the requirements of the law, corporate polices and procedures, and recognizing transactions that trigger reporting requirements under the law. Serving as the designated person to whom suspicious activity at retail locations is referred for further action. Please report the designation of your Compliance Officer on our AML Compliance Program Acknowledgements form (at the end of this handbook). You must complete this form and return to IPP initially and subsequently, whenever designating a new Compliance Officer. Internal Controls Your company needs to develop and maintain a system of internal controls designed to prevent, monitor and report potential money laundering. The first step is the adoption of an AML program by your senior management or Board of Directors. Your AML program should be reviewed and approved annually by your senior management or Board of Directors. Your AML program should include appropriate policies and procedures to address the following: Identification and reporting of unusual or suspicious activity Responding to government and law enforcement requests Collection and verification of customer identity (for transactions over certain amounts only) Monitoring and reporting of cash transactions that reach reportable thresholds Creating and retaining records, such as records of training, Transaction Reports and any supporting documents or records. You can use this handbook and/or materials from FinCEN (U.S. Treasury s anti-money laundering bureau) to develop your own AML compliance program and procedures. U.S Meta Payment Systems. All Rights Reserved 3

9 government agents may inspect your business to determine whether you have an effective compliance program. Training Program Your Compliance Officer is required to complete BSA/AML training prior to your company engaging in agent duties. In addition, your Compliance Officer must coordinate the training of all employees who are involved with day-to-day activities related to the bill payment service, prior to conducting any transactions. The level of training should be commensurate with the risks posed by the financial activities in which your business engages. Employees should be trained as part of new employee orientation and annually thereafter. At a minimum, employees should be trained as part of new employee orientation and annually thereafter. Training must be provided to each employee who accepts bill payments, but MPS recommends every employee in the business if feasible. Employee acknowledgement of participation in training and understanding of training must be kept on file. (See the end of this handbook for an Employee Acknowledgement of BSA/AML Training that can be used.) MPS takes failure to complete training in a timely fashion seriously. This failure may lead to progressive discipline, up to and including termination of your agent status. Retrain employees whenever a change is made to BSA regulations. AML employee training for bill payment must include the following (which are outlined in this handbook): Basics of how money laundering works and what terrorist financing is Government requirements dealing with anti-money laundering, including the Bank Secrecy Act and the USA PATRIOT Act Suspicious activity red flags Procedure for reporting suspicious activity Confidentiality requirements when reporting suspicious activity Procedure for reporting cash activity over $2,000 and $10,000. The completion of your initial and annual training must be indicated on the AML Compliance Program Acknowledgements form, which must be completed and returned to IPP. This form is found at the end of this booklet. Independent Review You should have an independent review of your AML program performed annually. Report the results of this review to your senior management and/or Board of Directors. This review must be performed by a party independent from your Compliance Officer and Compliance Department. It can, however, be performed by another officer or employee of your business. Alternatively, you may also engage an independent third party to perform the review. An adequate independent review includes consideration of the following: Overall integrity and effectiveness of the AML program, including policy, procedures and processes 2008 Meta Payment Systems. All Rights Reserved 4

10 Appropriate transaction testing to verify adherence to record keeping and reporting requirements Staff training Effectiveness of the suspicious activity monitoring systems Assessment of process for identifying and reporting suspicious activity, including a review of any Transaction Reports filed, if applicable After completion of your annual review, complete the AML Compliance Program Acknowledgements form and return to IPP. This form is located at the end of this booklet. Knowing Your Customers Knowing your customers is your most effective weapon against money laundering. Each payment center is required to implement a Know your Customer policy. Because customer identity is not established for bill payment transactions under $2,000, it is crucial to stay alert for any suspicious activity. Suspicious activity is discussed further in the next section. Requirements of your Customer Identification Program For this bill payment service, IPP is responsible for meeting the requirements of CIP and providing you with specific instructions on how to collect and verify required customer information. The following is provided for your basic understanding of CIP requirements, but IPP will give you the specific means to fulfill them. Customer Notification The customer must be notified that their identity will be verified prior to paying certain transaction amounts. IPP has provided you with a notice, which you are required to post in your location(s). The notice reads as follows: Federal law requires that customers for certain transactions be identified by name, address, government-issued identification and other relevant information. Therefore, customers may be asked to provide information and identification to comply with the law. Collection of Required Customer Information You are required to collect the following four pieces of information on each customer wishing to pay transactions exceeding $2,000 within a 24-hour period: 1. Name the full legal name of the customer 2. Date of birth for individuals 3. Address A residential or business street address (not P.O. Box), an Army Post Office (APO) or Fleet Post Office (FPO) box number, the residential or business street address of next of kin or of another contact individual, or a description of the customer s physical location Meta Payment Systems. All Rights Reserved 5

11 4. Government-issued identification number, such as a Social Security Number (SSN), Driver s license number, US or foreign passport number, US alien registration (green card) or Visa with photograph. Verification of Customer Identity After collecting these four pieces of customer information, the information must be verified to adequately prove the customer s identity to be true. The information must be verified enough to establish a reasonable belief of the customer s identity. You must verify identity through physical review of an unexpired government-issued identification (ID) that contains a photograph. Verify the photo likeness of the person and whether or not the ID is valid or appears to be altered. The Transaction Report form is located at the end of this booklet. This form should be used for transactions exceeding $2,000, for suspicious activity, or for cash transactions over $10,000. (discussed below) To further verify the information, you are required to fax a Transaction Report, copy of the remittance advice and a copy of the customer s ID to IPP s Compliance Department. The Transaction Report form can be found at the end of this booklet. IPP uses a Third Party Database Verification (non-documentary) method, which means customer information is verified by using a third party database. Comparison to Government Lists - OFAC The Office of Foreign Asset Control (OFAC) is a department of the U.S. Treasury that administers and enforces economic and trade sanctions against individuals, entities, or countries. The OFAC regulations require all businesses to identify and freeze the assets of oppressive governments, international terrorists, narcotic traffickers and other specially designated persons identified by OFAC. OFAC maintains a list called Specially Designated Nationals and Blocked Persons (SDN) list. Any type of transaction involving a party listed on the SDN list must be prohibited. IPP is responsible for checking all customers against the SDN list on your behalf. CIP Recordkeeping IPP will instruct you on your CIP recordkeeping responsibilities, depending on the system or terminal used. All supporting documentation, such as the remittance advice and copy of photo identification, must be kept for five (5) years. You may be asked to submit records to MPS upon request. Unusual or Suspicious Activity Key goal: to identify, record, and report suspicious transactions or activity. One key goal of an AML program is identifying, recording and reporting suspicious transactions or activity. There is no clear cut definition of suspicious activity, what may appear or seem suspicious for one customer may be normal and appropriate for another. That is why it is important for you to understand your customers, and their normal use of your financial services. Suspicious activity as it relates to electronic payments can be difficult to identify. The following are examples of activities that would be considered suspicious: 2008 Meta Payment Systems. All Rights Reserved 6

12 Multiple customers come in together and seem to be breaking a larger sum of money into smaller amounts in order for each to be able to make a payment under reporting thresholds. A customer who typically makes small payments has an unusually large amount of cash and is conducting large transactions for no apparent legitimate reason. A customer uses two or more payment centers or cashiers in the same day in order to break one transaction into smaller ones. A customer wants to exceed the velocity limits with one transaction, or attempts to break up the transactions into a number of smaller payments. A customer offers bribes or tips. A customer admits to illegal activity. Customer uses false identification. The customer wants to void the transaction once identification is requested or required. Notify IPP no later than 6 pm EST on the day you initially detect suspicious activity. Reporting Suspicious Activity Transaction Report Your compliance program should contain procedures and training on detecting and reporting suspicious activity. You are required to notify IPP no later than 6 pm EST on the day you initially detect suspicious activity by completing a Transaction Report. This report, as well as any supporting documentation must be sent to IPP per instructions provided on the report form. A Transaction Report should automatically be completed for multiple transactions exceeding $2,000 regardless of whether or not it seems suspicious. The Transaction Report should be completed as thoroughly as possible with the information available. Be specific. Include all information about the transaction, even if it seems secondary. Question: What can I send as supporting documentation? Anything used in your investigation should be sent to IPP. This may include such items as remittance advices, copy of customer s identification, receipts, witness statements and/or a description of any other records that may be available (e.g., video surveillance or audio recordings). Confidentiality Information regarding the reporting of suspicious activity is highly confidential and should be shared internally only on a need-to-know basis in order to minimize the risks of inadvertent disclosure. Never tell your customer that you reported suspicious activity - it is illegal to tell any person involved in a suspicious transaction that a Report has been filed. If anyone were to inquire about suspicious activity, refer them to the IPP Compliance Department by calling or contact your Compliance Officer. MPS staff may contact you to assist in an investigation of the customer's transactions. You may not tell the customer that they are the subject of an investigation Meta Payment Systems. All Rights Reserved 7

13 Recordkeeping All records related to Transaction Reports should be centralized with your Compliance Officer for a period of five (5) years from the date of detection. MPS will also maintain records in accordance with its legal requirements. Safe Harbor A BSA provision, called safe harbor, provides protection from civil liability to your business and employees for all suspicious activity reporting. Federal law will protect any person that reports suspicious activity as long as good faith is demonstrated (i.e. you truly believe a transaction is suspicious and provide the information honestly). If an employee does not report suspicious activity due to willful blindness (he/she had knowledge of the reportable activity but intentionally doesn t report it), there may be a liability. If you locate or later remember a transaction that was not reported, a late report is better than not reporting. Question: A customer wants to make multiple payments over $2,000. The cash he gives is in small denominations. When the staff member inquires as to where he got the cash, the customer begins to get angry. Should any action be taken? Advise the customer that you just need to understand the transaction fully before you can complete it. Ensure that necessary ID and address information is recorded for Transaction Report form. If provided, complete transaction. If not, do not conduct transaction. Report suspicious activity once customer has left, and keep Transaction Report confidential. Currency Transaction Reporting Requirement: File a Transaction Report for any cash transactions of more than $10,000 made in one day. The BSA requires the reporting of any cash transactions of more than $10,000 ($10, and over) made in any one day by any person or on behalf of another person. This requirement does not need to be kept confidential. Before conducting any transaction that meets the $10, and over reporting threshold, you must complete a Transaction Report for each party conducting the transaction(s): 1. Visually review a valid, unexpired government-issued identification that contains a photograph, such as a driver s license or passport, and verify customer s identity. 2. Complete the Transaction Report and submit to IPP per instructions found on the form. The following information must be obtained at the time the form is completed: Name Address Social Security Number (SSN) or other government-issued identification number Date of Birth Occupation If you believe the information provided is false, do not complete the transaction and file a Transaction Report for suspicious activity if applicable Meta Payment Systems. All Rights Reserved 8

14 If you sell a number of products that would add up to an amount that s reportable, necessary documents must be filed. Aggregation You must treat multiple cash transactions made in one day as a single, aggregate transaction for reporting purposes. This includes transactions involving different products or services as well as transactions made across your locations. For example, the following scenario would require you to fill out a Transaction Report: Example: A customer enters your payment center location looking to pay his American Express bill for $1,800, Visa bill for $1,800, MasterCard bill for $1,800, utilities bill for $2,000, phone bill for $2,000 and purchase prepaid wireless cards for $1,000 for a total of $10,400. The clerk must first obtain customer identification for completion of the Transaction Report. Question: When will we have knowledge of multiple transactions conducted by or on behalf of the same person? If you or your employee witness the multiple transactions If someone tells you or an employee about the multiple transactions If you or an employee know a customer is conducting a transaction for someone else for whom you or your employee know has already conducted another transaction Question: What should I tell a customer that doesn t want to provide necessary information? Federal anti-money laundering regulations require that we get this information. As much as we want your business, regulations require that we collect information for purchases made with this amount of cash. I can t complete this transaction without more information. If you would like to discuss this further, I ll have you speak to our AML Compliance Officer. Decline a transaction if the customer is unable or unwilling to provide the identification documents or personal information required. You may need to file a Transaction Report for suspicious activity in some cases. Recordkeeping You must retain copies of all records related to Transaction Reports for a period of five (5) years from the date of the report. All record keeping should be centralized with your Compliance Officer. MPS will also maintain all records in accordance with the BSA Meta Payment Systems. All Rights Reserved 9

15 Summary of To Do Items To comply with all applicable anti-money laundering regulations, please complete the following: Designate an AML Compliance Officer for your location Implement an AML compliance program and procedures Complete AML training for all front-line employees (prior to conducting transactions and annually thereafter) Complete an annual independent review of your AML compliance program Complete the AML Compliance Program Acknowledgements form and return to IPP (initially and annually thereafter) Ongoing Responsibilities: Collect required customer information for certain transaction amounts Report suspicious activity (on Transaction Report form) Submit Transaction Report form for aggregate transactions exceeding $2,000 in cash within a 24-hour period Submit Transaction Report form for aggregate transactions over $10,000 in cash within a 24-hour period Fulfill recordkeeping requirements Contact Information Jani Gode, C.A.M.S. Assistant Vice President BSA/AML Officer 5501 S. Broadband Lane Sioux Falls, SD Phone: Fax: jgode@metapay.com Stacy Surat BSA/AML Program Administrator 5501 S. Broadband Lane Sioux Falls, SD Phone: Fax: ssurat@metapay.com 2008 Meta Payment Systems. All Rights Reserved 10

16 IPP TRANSACTION REPORT Use This Form to Document Transactions Exceeding $2,000 Check Box(es) that apply: Single Transaction Multiple Transactions Multiple Persons PART 1 - PERSON PROCESSING TRANSACTION t ti Section A Sender information Individual s Last Name Individual s First Name Individual s Middle Initial Address (#, street, apt, city, state and zip code) Date of Birth Occupation Soc - Sec - No Driver s License Alien Registration Passport Other Section B Account holder information if different than above (if applicable) Individual s Last Name Individual s First Name Individual s Middle Initial Address (#, street, apt, city, state and zip code) Date of Birth Occupation Soc - Sec - No Drive r s License Alien Registration Passport Other PART 2 RECEIVER/VENDOR INFORMATION FULL NAME Address (#, street, apt, city, state and zip code) Account Number (if applicable) PART 3 PAYMENT CENTER WHERE TRANSACTION TAKES PLACE Name Payment Center Number Address (#, street, city, state and zip code) Telephone Fax Name of Person Executing Transaction Date Send IPP Tra nsaction Report to IPP Operations, Fax No

17 Employee Acknowledgement of BSA/AML Training I acknowledge that I have received training on the requirements of compliance with our Anti-Money Laundering (AML) Compliance Policy and Meta Payment Systems (MPS) AML requirements for agents. By signing below, I agree that I have reviewed and understand the materials given to me. I also agree it is my responsibility to comply with all regulations that are set forth by the Bank Secrecy Act and the USA PATRIOT Act. Dated this day of 20 Signature Print Name Print Supervisor s Name Name of Business Address of Business Phone Number Keep this completed form with your employee BSA/AML records Meta Payment Systems. All Rights Reserved

18 AML Program Compliance Acknowledgements By signing this acknowledgment, I hereby state that (Company) has implemented an Anti-Money Laundering (AML) Compliance policy, will comply with all reporting and recordkeeping requirements imposed by the Bank Secrecy Act, USA PATRIOT Act, and any other applicable AML laws or regulations, and has completed the following requirements in accordance with Meta Payment Systems (MPS) AML requirements for agents. AML Compliance Program / Policy Reviewed and Implemented Dated: Appointment of an AML Compliance Officer Name: Date Appointed: Phone Number and/or Address: Completion of Initial and Annual AML Training for Employees I acknowledge that all employees have been (or will be) trained prior to conducting any transactions, at the time of hire and annually thereafter. Date Annual Training was Completed: Annual Independent Review Completed Date of Annual Independent Review: Acknowledged By: Signature: Printed Name and Title: Company: Date of Acknowledgement: MetaBank Agent No.: Submit this form to IPP initially and annually thereafter. Fax to IPP Compliance at (973) or mail to 330 Passaic Avenue, Fairfield, NJ Meta Payment Systems. All Rights Reserved