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BSA/AML Recordkeeping Requirements for Wire Transfers, Money Orders, and Other Transactions


Gain deeper insight into BSA-AML requirements and what must be saved and for how long.

Banks and other financial institutions are required by the Bank Secrecy Act (BSA) to maintain records for various types of transactions. Recordkeeping requirements may differ depending on the type of transaction and the role of the institution in the particular transaction. Failure to comply with applicable recordkeeping requirements can subject a financial institution to monetary penalties and other regulatory consequences. This topic will provide an overview of the BSA's recordkeeping requirements and discuss the requirements for funds transfers, monetary instruments, and certain other types of transactions. This information should help you understand when various types of transactions trigger recordkeeping requirements and what information must be collected and retained.



Javier A. Urbina

Javier A. Urbina

Skadden, Arps, Slate, Meagher & Flom LLP

  • Associate with Skadden, Arps, Slate, Meagher & Flom LLP
  • Advises global financial institutions and multinational companies with respect to issues arising under U.S. anti-money laundering and economic sanctions laws
  • Extensive experience representing clients on domestic and complex cross-border compliance and enforcement matters, including internal investigations, regulatory examinations, transactional due diligence, voluntary disclosures, monitorships, and the resolution of administrative and enforcement proceedings involving federal and state regulatory and law enforcement agencies
  • In addition to representing clients in investigations and contested proceedings, he regularly works with clients to design and implement strong global, regional, and local compliance programs to address requirements imposed by U.S. anti-money laundering laws and economic and trade sanctions regulations
  • Advises major companies in the fintech/virtual currency spaces in connection with money transmission and similar licensing requirements, as well as related compliance obligations under applicable anti-money laundering and sanctions regulations
  • Recently completed a secondment in the headquarters of a global European-based bank, where he advised on obligations arising from the bank’s sanctions settlements with U.S. federal and state authorities, and assisted in developing and implementing an enhanced global sanctions compliance program
  • J.D. degree, with high honors, George Washington University Law School; B.A. degree, University of Pennsylvania

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