Notes and Topics

Stand-Up Script

Overview

Over the past several years you have been learning about compliance with federal anti–money laundering laws, commonly referred to as the Bank Secrecy Act. You have learned that customers must complete PS Form 8105-A, Funds Transaction Report, when they purchase $3,000 or more in money orders during the same day, and that you must complete a PS Form 8105-B, Suspicious Transaction Report, when you suspect that customers might be using money orders to launder proceeds from illegal activities.

Thanks to your efforts, the Postal Service has made tremendous strides in complying with the laws. We have gained the respect of our regulators and law enforcement agencies alike. But we need to fine-tune some of the procedures to make us even better. Following are some important points to keep in mind when completing PS Form 8105-A and PS Form 8105-B.

PS Form 8105-A

Let’s start with PS Form 8105-A. It is very important that the form is complete and accurate in order for the Postal Service to stay in compliance with federal laws.

Date of Birth

Make sure the complete date (including the year) is recorded accurately on the form.

Social Security Number

The only acceptable substitutions are: Tax Identification Number (TIN), Employer Identification Number (EIN), Passport Number, and Alien Registration Number.

Military IDs

Note: Military IDs are no longer acceptable replacements for Social Security Numbers.

Other IDs

Acceptable “other government IDs” include: local-, state-, and federal-issued photo identification if they contain a unique number. Examples include local, state, and federal law enforcement IDs, and Indian tribal IDs

Non-Government Issued IDs

Note: Credit cards, library cards, company (employment) IDs, club cards, such as Wal-Mart, Sam’s Club, etc., are not acceptable “other IDs”, even if they have photographs on them.

Other ID Type

If “other government ID” is used, the type of photo ID must be entered on the form.

Complete Customer Information Needed

If customers refuse to provide all required information, you must refuse to sell the money orders.

Awareness of Previous Money Order Purchases

If you are aware that the customer has purchased money orders from another office (or another person in your office) and if the purchase being made combined with the other purchase(s) during the day is $3,000 or greater, a PS Form 8105-A must be completed.

PS Form 8105-B

Let’s review a few key points about PS Form 8105-B. The training video provides you with the top 10 things to remember about reporting suspicious activities. Keep these things in mind as you are filling them out.

Reasons for Suspiciousness

The reasons for suspiciousness must be indicated — Box 1, 2, and/or 3 must be checked. If none of those boxes apply, the comments must contain sufficient detail to indicate why the transaction is suspicious.

Full Description of Suspicious Activity

Simply checking Box 4, the “Other box”, is not sufficient, even if a detailed description of the individual(s) is provided.

Handwriting

Comments must be legible. The BSA team recommends printing instead of script.

Minimum PS Form 8105-B Information

Each form should, at a minimum, have the age and gender of the customer(s) and the time of the transaction.

Wrap-up

This year’s training video is an excellent reminder of a few of the top things to remember about suspicious activities. The training provides examples of how we can stay alert to money laundering activities and keep the Postal Service in compliance with federal laws.

Your work in this area is making a difference and is very important. Thank you for your efforts and let’s continue to keep a sharp eye out for potential money launderers.