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Compliance at Travelex

Travelex Currency Services Inc (“TCSI”) is registered at the federal level with the Financial Crimes Enforcement Network (“FinCEN”), as a money services business (“MSB”) and is based in New York’s historic Wall Street District. TCSI is an ultimate subsidiary of Travelex Holdings Limited (“Travelex”) in the United Kingdom.

TCSI is subject to comprehensive regulation by FinCEN and the various state regulators in whose jurisdictions we are regulated (see list of licenses on Licensing page).

Commitment to Compliance

TCSI acknowledges the importance of all relevant laws, rules, regulations, policies and standards - whether internal or external - and complies with them. We are committed to strict management discipline and a first-class control and compliance environment. As a regulated entity, TCSI is required to meet strict financial standards, including capital adequacy requirements. We are also required to routinely submit financial reports to our regulators. These standards and others are rigorously enforced by FinCEN and the various state regulators, which have the right to fine firms and/or terminate their regulatory status for violations. In this effort, TCSI has implemented a comprehensive compliance program to handle money laundering concerns and adhere to OFAC regulations.

Money laundering is the process by which persons or businesses attempt to conceal the origin and ownership of the proceeds of illegal activity such as fraud, theft, drug trafficking, or any other crime. Money laundering may also involve the use of legitimately derived funds to finance terrorism. Various financial products and transactions, including those related to the foreign exchange market, may be involved in money laundering schemes. Accordingly, we are aggressive in not allowing TCSI to be used as a vehicle for such activity. Money laundering is a criminal offense and can subject its perpetrators and/or facilitators to substantial criminal and civil sanctions, including imprisonment and fines. To ensure compliance with anti-money laundering laws and regulations, TCSI has implemented policies and procedures to detect, prevent and report money laundering or other suspicious activity.

The Office of Foreign Assets Control administers and enforces economic sanctions programs primarily against countries and groups of individuals, such as terrorists and narcotics traffickers. The sanctions can be either comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals. TCSI conducts electronic screening of customer transactions through U.S. government and other sanctioned party lists.

Ethical Conduct

Travelex is committed to maintaining the highest level of professional and ethical standards in the conduct of its business affairs. It is critical we maintain our strong reputation for honesty and integrity. These have been core values of Travelex since it was founded in 1976.

TCSI is subject to Travelex’s Global Ethical Conduct policies which ensure full compliance with the Foreign Corrupt Practices Act (“FCPA”) and the UK Bribery Act.

All colleagues and representatives are empowered and expected to raise any concerns that they may have regarding any possible illegal activities or misconduct that they encounter in their work environment.

All employees must attest to their understanding of these prohibitions at the time of hire.

Know Your Customer

Our Accreditation function is currently responsible for operating and implementing the Travelex Currency Services "Know Your Customer" Risk-Based Accreditation Policy and Currency Services Credit Risk Policy. The goal of Accreditation is to ensure that all client records, including both contract and credit information, are properly updated and maintained as mandated by state and federal anti-money laundering guidelines. Additionally, our internal focus falls on providing guidance and support to both Retail Store Managers as well as Outsourcing Relationship Managers concerning any questions pertaining to contracts, accreditation, reaccreditation, and credit limits for all of our 1000+ Currency Services clients across the Americas.

Our Field Examination function is responsible for reviewing the effectiveness of all U.S., non-bank agent compliance programs and ensuring that they are in adherence with all state and federal AML regulations and Know Your Customer best practices and recommendations. In addition, examiners are also responsible for visits to Travelex retail locations in high risk locations, with the purpose of ensuring the soundness and understanding of our own internal compliance and AML policies. Periodically, we will use our findings to revise and update existing policy documents which include agent handbooks, management policies, and any other related or applicable documents. The goals of Field Examination are to see that all non-bank agents, as well as internal Travelex representatives, are acting within the guidelines and regulations governing currency exchange or money transmittal services, and to work in conjunction with management to ensure that any actions outside of those guiding principles are assigned a suitable, timely resolution. 

Partners

As a provider of foreign currency products and a partner or authorized agent of Travelex, adherence with federal regulations pertaining to our services is of utmost importance. Many of those regulations include reporting requirements which involve detailing information from specific transactions for review by federal or state officials. In order to facilitate ease of reporting for our agents, we have placed links to a few commonly used reporting forms, below. Additionally, the FinCEN Form 111 Suspicious Activity Report and FinCEN Form 112 Currency Transaction Report are required to be filed electronically via the BSA E-File website. Each of these forms has a purpose, specific to individual sales or occurrences that may arise during the course of business. Please ensure that you carefully review any and all form instructions prior to submission. If you have any questions regarding the use of these forms, please contact Travelex Currency Services Compliance for additional guidance.     

 

Travelex Currency Services Inc has various corporate services available though our Retail network. Any corporate entity interested in conducting currency transactions may inquire about services and availability at their closest Travelex Retail Branch Location. All Retail Corporate Client may be subject to an application process, pending approval by Travelex Compliance.