Important Notice: New FinCEN Reporting Requirements for Southwest Border MSBs

Effective April 14, 2025: FinCEN has issued a Geographic Targeting Order requiring money services businesses in specific southwest border zip codes to report currency transactions between $200-$10,000 and verify customer identities. If applicable, contact sales@alltrustnetworks.com or help@alltrustnetworks.com to convert to Smart Check. Learn More

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OFAC & SDN List via Check Cashing

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When it comes to check cashing, the Office of Foreign Assets Control (OFAC) and the Specially Designated Nationals (SDN) List are highly relevant for compliance and risk management. Here’s how they intersect:


1. Compliance with OFAC Regulations

Businesses involved in check cashing, such as financial institutions, money service businesses (MSBs), and retail check-cashing outlets, must comply with OFAC regulations. This means they are required to ensure that they do not process transactions or provide services to individuals or entities on the SDN List or those subject to sanctions.


2. Screening Transactions

Check-cashing businesses must screen:

  • The payee of the check
  • The issuer of the check
  • Any associated parties
    against the SDN List and other OFAC sanctions lists. This ensures that they are not facilitating transactions for sanctioned individuals, entities, or countries.

3. Risk of Penalties

Failing to comply with OFAC regulations can result in:

  • Civil penalties: Fines for unintentional violations
  • Criminal penalties: Severe consequences for willful violations
  • Reputational damage: Loss of trust from customers and partners
    Check-cashing businesses must have robust compliance programs to avoid these risks.

4. Due Diligence and Recordkeeping

Check-cashing businesses are required to:

  • Conduct due diligence on customers and transactions.
  • Maintain detailed records of transactions to demonstrate compliance with OFAC regulations.
  • Report any suspicious activity or potential matches to the SDN List to the appropriate authorities.

5. Technology and Automation

Many check-cashing businesses use automated systems to:

  • Screen customers and transactions against the SDN List in real time.
  • Flag potential matches for further review.
    This helps streamline compliance and reduce the risk of human error.

6. Protecting the Financial System

By adhering to OFAC regulations, check-cashing businesses help prevent:

  • Money laundering
  • Terrorist financing
  • Other illicit activities
    This contributes to the overall integrity and security of the financial system.

In summary, check-cashing businesses must integrate OFAC compliance into their operations to avoid legal and financial risks while supporting broader efforts to combat financial crimes and enforce sanctions.

Disclaimer: The information provided in this document is for informational purposes only and should not be considered legal advice. Check-cashing businesses are encouraged to consult with legal professionals or compliance experts to ensure full adherence to OFAC regulations and other relevant laws.

About AllTrust Networks

AllTrust Networks is the nation’s leading innovator of software and services for check cashing and alternative financial services solutions. Thousands of retailers use AllTrust for risk management and check processing, benefiting from AllTrust’s extensive databases of consumers and check maker networks. AllTrust manages the country’s largest consumer biometric database, with over 10 million enrolled customers and has processed more than $60-billion in checks. Headquartered in Herndon, VA, AllTrust is committed to serving the alternative financial services community.

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