Fiscal Year 2008 Anti–Money Laundering/Anti–Terrorist Compliance Training Course Number 18201-30

To combat money laundering in the United States, Con­gress has enacted a series of laws collectively known as the Bank Secrecy Act (BSA). The Postal Service™, as a seller of money orders, is specifically named in the act and must comply with all of the requirements of the law. Under the act, the Postal Service is required to do the following:

To meet the compliance mandate of the Bank Secrecy Act and the USA PATRIOT Act, the Postal Service must provide ongoing training to those employees who sell postal financial instruments. If found to be in noncompli­ance with the law, the Postal Service could face civil pen­alties of $25,000 per occurrence for each unreported transaction and also $25,000 for each day and for each office that is not in compliance. In addition, criminal penal­ties can be imposed against the Postal Service or any of its employees in an amount up to $250,000 and a prison sen­tence of up to 5 years.

The purpose of this training is to provide retail associ­ates, managers of postal operations, postmasters, relief postmasters, officers-in-charge, station managers, and supervisors with an understanding of the anti–money laun­dering (AML) policies and procedures including the BSA, the USA PATRIOT Act, and policies and procedures required under current legislation. This training will include updates on the AML program as well as Postal Service AML system and procedure changes.

Following is the stand-up talk for the fiscal year (FY) 2008 BSA/AML training, which is included in the FY 2008 Strategic Training Initiative list of legally required training. The target audience for this training is all retail associates and those managers of postal operations, postmasters, station managers, branch managers, and supervisors who sell financial instruments or manage employees who sell these instruments. The FY 2008 training, comprised of a DVD and stand-up talk, is designed to be given by a post­master or postal supervisor. The scripted stand-up talk should be given prior to showing the DVD.

The training packets are being sent directly to all Post Offices™, stations, and branches in mid-January. If you do not receive a copy of the training packet by February 15, or if you have questions, please send an e-mail to

Workhours for this training are being rolled out to the area and district offices in January.

Stand-up Talk


It is extremely important that the Postal Service stay in compliance with federal anti–money laundering laws, com­monly referred to as the Bank Secrecy Act. Customers must complete a PS Form 8105-A, Funds Transaction Report, when they purchase $3,000 or more in money orders during the same day. Retail associates must com­plete a PS Form 8105-B, Suspicious Transaction Report, when they suspect a customer might be using money orders to launder proceeds from illegal activities.

Thanks to your tremendous efforts, the Postal Service has made phenomenal strides in complying with the laws. We have gained the respect of our regulators and law enforcement agencies alike. However, we need to fine-tune some of the procedures to make us even better.

Today I want to reinforce some points made in the cur­rent training video and touch on a few points that the video doesn’t cover.

PS Form 8105-A

Let’s start with PS Form 8105-A. It is very important that the forms are 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

We realize that customers may be hesitant to provide their Social Security numbers. But the law is very clear that if customers refuse to provide their Social Security numbers when required, or to provide an acceptable substitute, associates simply may not conduct the transaction. Remember that the only acceptable substitutions for the Social Security number are: a tax identification number (TIN); an employer identification number (EIN), a passport, and an alien registration number.

Military IDs

Military IDs are no longer acceptable replacements for Social Security numbers. However, military IDs are acceptable photo identifications.

Other IDs

Only US government–issued IDs are acceptable as “Other IDs.” Acceptable 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.

Note: There is one exception to the U.S. government–issued ID rule: Matricula Consular identifications issued by the Mexican Government are acceptable types of “Other ID.”

Non-government–issued IDs

Non-government photo IDs are not acceptable. Examples of non-acceptable photo IDs are credit cards, library cards, company (employment) IDs, club cards, such as Wal-Mart, Sam’s Club, etc., 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 a customer refuses 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 postal money orders from another Post Office (or another associate in the same office) and if the purchase being made combined with other purchases during the day is $3,000 or greater, a PS Form 8105-A MUST be completed.

Two or More People Working Together

If two or more people are working together to purchase money orders and EACH person purchases less than $3,000, none of the customers need to complete PS Form 8105-A, even if the total purchase for all customers is $3,000 or greater. But this could necessitate a PS Form 8105-B as detailed in the accompanying video.

PS Form 8105-B

Let’s review a few key points about PS Form 8105-B, Suspicious Transaction Report.


Round Date Stamp

A legible round date stamp must be applied to each form submitted.

Reasons for Suspiciousness

The reason 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, “Other”, is not sufficient, even if a detailed description of the individual(s) is provided.

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

Notifying Customers

Under no circumstances should you alert the customer to the fact that a PS Form 8105-B will be submitted. You are reporting a suspicious activity, and you must not let the customer know that you are filling out a PS Form 8105-B.

Use of PS Form 8105-B

PS Form 8105-B is helpful to criminal investigators like the postal inspectors and other law enforcement agents. The form helps identify potential money laundering activities and is often very important in building a criminal case. Although filling out a form does not guarantee that an investigation will always be launched or that a prosecution or conviction of any individual customer will happen, it is a very useful tool for law enforcement and has been instrumental in identifying criminal activity. Your help in filling out these forms completely and accurately every time you recognize a suspicious transaction might be the start of putting some heavy-duty criminals behind bars.

Contact the BSA Office

Call the BSA Compliance Office at 717-630-2347 if there are any questions regarding the proper completion of PS Forms 8105-A or 8105-B. You can also e-mail your questions to


There’s a good chance you will remember many of the scenes in this year’s training video because it is a compre­hensive review of the key points made in training materials over the past few years. We picked the best examples of how we postal employees can stay alert to money launder­ing activities and keep the Postal Service in compliance with federal laws. This is a top ten list that is worth remem­bering.

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.