Finance

Contract Postal Unit Anti–Money Laundering and Anti–Terrorist Compliance Training Released

All Postal Service™ managers responsible for the administration of contract postal units (CPUs) are reminded that CPU personnel who sell money orders must comply with all federal laws and regulations and with postal policies related to anti–money laundering and anti–terrorist initiatives.

Federal anti–money laundering and anti–terrorist laws and regulations (commonly referred to as the Bank Secrecy Act and the USA PATRIOT Act) mandate that the Postal Service implement a comprehensive Anti–Money Laundering/Anti–Terrorist Program (AML/ATP). To satisfy this legal mandate, the Postal Service has developed a CPU training packet that consists of a Bank Secrecy Act (BSA) training video and manual. These packets were mailed to each CPU in early December

Postal Service managers responsible for CPUs must ensure that the contract unit receives the BSA training material. CPU managers must ensure that:

1. All CPU personnel who sell postal money orders and the CPU managers who supervise them must view the BSA training video and review the training stand–up talk.

2. All CPUs that sell postal money orders maintain a supply of PS Forms 8105-A, Funds Transaction Report, and PS Forms 8105-B, Suspicious Transaction Report, and that the forms are readily available to personnel who sell money orders.

3. CPU personnel send completed PS Forms 8105-A and PS Forms 8105-B to the address on the bottom of the forms the day the forms are completed.

A copy of the stand-up talk that was mailed to the CPUs is included in the following pages. We asked each office to report to the BSA Compliance Office once their training is complete by sending an e-mail to lisa.m.williams@usps.gov or by calling Lisa at 202-268-3773.

For additional packets, or if you have questions, please send an e-mail to BSA@usps.gov.

Note: CPU personnel who do not sell postal money orders do not need to take the training.

Contract Postal Unit Training Stand-Up Talk

Overview

During 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 Forms 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 Forms 8105-A, and PS Forms 8105-B.

PS Form 8105-A

Let’s start with a few key points about PS Form 8105-A, Funds Transaction Report. 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	The only acceptable substitutions are tax identification number (TIN), employer identification number (EIN), passport number, and alien registration number.
Military IDs	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 are local, state, and federal law enforcement IDs, and Indian tribal IDs.
Non-government–issued IDS	Credit cards; library cards; company (employment) IDs; club cards, such as Wal-Mart and Sam’s Club 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 the 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 money orders from another office (or another retail associate in the same office) and if the purchase being made combined with other purchases during the day is $3,000 or greater, you must complete PS Form 8105-A.

PS Form 8105-B

Now, let’s review a few key points about PS Form 8105–B, Suspicious Transaction Report. In the video, a BSA team member describes why a correct and complete form is so important. Keep these things in mind as you are filling them out.

 

Round Date Stamp	A legible round date stamp must be applied to each submitted form.
Reasons for Suspiciousness	The reasons for suspiciousness must be indicated — Boxes 1, 2, and/or 3 must be checked. If none of those boxes apply, the Comments section must contain sufficient detail to indicate why the transaction is suspicious.
Full Description of Suspicious Activity	Simply checking Box 4, Unusual Activity, in the Comments section 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 8105-B Information	Each form must, 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 suspicious scenarios that occur in real life. Remember, the accounts illustrated in the video actually happened and the silhouetted retail associates in the video were the actual people involved, not actors. They are excellent examples of how we as Postal Service employees 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. Let’s continue to keep a sharp eye out for potential money launderers.

— Corporate Treasury,
Finance, 1-17-08