Enforcement: FinCen sanctions money transmitter Sarith Meas
Sarith Meas has entered into an agreement to pay a civil money penalty without admitting or denying FinCEN's findings that she operated a money transmitting business in breach of, inter alia, the Bank Secrecy Act.
FinCEN says that, from January 2006 until the end of October 2010, Meas acted as an independent money transmitter, located in Westbrook, Maine and executed funds transfers for customers and received financial compensation for those money transmission services. Meas engaged in the business of transmitting funds for persons located in the United States. At all relevant times, Meas was a “money transmitter,” within the meaning of the BSA and its implementing regulations.
In a typical transaction, a customer provided Meas with cash, cheques, or money orders, along with instructions to transmit funds to a specified beneficiary and Meas deposited those funds into her U.S. bank accounts.
Once the funds cleared, Meas instructed U.S. financial institutions to wire transfer funds to designated financial institution(s) in Cambodia — a jurisdiction classified by the United States Department of State as suffering from money laundering deficiencies— where the funds were retrieved by Meas’ affiliate(s) and made physically available to beneficiaries in the designated currency.
For an extended period of time, Meas operated as an independent money transmitter by engaging as a business in the transfer of funds. She was required under the BSA to register as an MSB with FinCEN and implement a written anti-money laundering system.
To resolve this matter, and only for that purpose, Meas, without admitting or denying either the facts or determinations described by FinCEN, except as to jurisdiction, which is admitted, consented to the assessment of a civil money penalty in the sum of USD12,500 to be satisfied by five equal installments of USD2,500 to the United States Department of the Treasury.
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