Banking Background Investigations and Foreign Currency Exchange Licenses
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Any application to organize or control a financial services entity, such as a Foreign Currency Exchange company, requires a detailed banking background investigation. Banking background investigations are critical to make sure the money services business is properly monitoring transactions to deter money laundering, terrorist funding, or financial crimes from occurring. Many applications are denied due to certain requirements not being met. The confusion lies in the fact that many states have subtle differences in the background report certification checklists and there are different applications for various money services within a state.
For example, Texas has two types of money services business licenses and separate applications for each type. There is one application for money transmission and a different application for currency exchange only. According to the Texas Banking Department, “the money transmission license includes 1) issuing or selling prepaid access cards and instruments such as checks, money orders and traveler’s checks; 2) receiving money for transmissions; 3) providing third-party bill paying services; 4) transporting currency; or 5) currency exchange. In Texas, a business that engages only in currency exchange must have a currency exchange license.”
In this case, although the applications were different, the background investigation report requirements were the same and included the basic Search Firm Report Checklist required by the Texas Department of Banking
- A comprehensive credit report/history including the actual credit report as well as a summary.
- Civil court and bankruptcy court records for the past 10 years, including a search of court data in the country, states, towns, where the individual resided and worked in the contiguous areas.
- Criminal records including felonies, misdemeanors and violations including a search of cout data in the country, states, towns, where the individual resided and worked and in contiguous areas
- Employment history
- Media history including an electronic search of national and local publications, wire services and business publications
- Regulatory history, particularly securities, insurance, mortgage-related, real estate, etc., if applicable
- Judgments and liens filed against the individual in the last 10 years (primary search would be in the areas listed above in 2 and 3)
- Licenses granted by any governmental agency or judicial body; indicate if they are current and in good standing
The list above demonstrates the banking background investigation report most states require. It’s important to know the search requirements for various applications and in various states. For example, the required background investigation information for a New York State Department of Financial Services application to organize a financial services entity includes all of the above and Education Records, Personal and Professional References, Department of Motor Vehicle records and a Listing of all Credit Relations by the applicant such as revolving credit. It is the responsibilty of the money services business and its principles applying for a license to order the investigative background reports at their own expense from an independent licensed private investigation company. Some states require the report to be accompanied by a summary letter which identifies the scope of the search, indicates the independence of the search firm from the individuals and the application, and identifies contact information should a question arise.
If the state or country’s specific banking background investigation reports are not met, the application is rejected which is why it is critical to hire a reputable independent licensed private investigation company that is experienced and knowledgeable about the requirements in each state and/or country. Applicants who hire Alliance Risk Group for their banking background investigation services are required to complete and sign a background investigation release form permitting the company to conduct a comprehensive review of the applicant’s background information. Alliance conducts background investigations that comply with banking background investigation requirements nationally as well as in many countries including Australia and other states throughout the US. For more information on Foreign Exchange license requirements, money services businesses and background report certification checklists, complete this form and a representative will contact you shortly!