Regulation

REGULATION AND TRANSPARENCY

Envios 22-24 depends on a close relationship with its customers.  Throughout its 30+ year history, 22-24 has maintained the trust and confidence of its Nicaraguan client base. In a sea of sharks providing one-time financial services to customers, 22-24 has focused on providing a more personalized experience to its clients. The term “money services business” includes any person doing business as a Money Transmitter. Envios 22-24 must follow regulation outlined in the Bank Secrecy Act (BSA) as well as other statutes. While these rules are not a secret, no other service we know of openly discloses the terms of these regulations to their customers. In an effort to provide our customers with straight-up transparency, below is a short summary of the most important aspects of regulations that affect our client base or anyone transmitting funds overseas.

Note: The summary on this page is not a complete or comprehensive list or rules, doesn’t include rules found in other regulation such as the Patriot Act, and doesn’t include measures we may take internally to prevent or reduce fraud. The summary below is based on regulation applying to US consumers and money service businesses acting as money transmitters. For more information about regulation and you as a US resident, please visit the Financial Crimes and Enforcement Network (FinCEN) website at fincen.gov. Envios 22-24, S.A is a registered money transmitter in Nicaragua. For regulatory information for our customers/affiliates in Nicaragua, please visit our Nicaraguan Compliance page here.

YOUR PERSONAL INFORMATION AND TRANSACTION LIMITS

Envios 22-24 exceeds the requirements of the law in order to keep your personal and financial information safe. We encrypt all customer information on our servers. If personal information is not required to provide you service, we encrypt and air-gap your data anyway.

Requirements for customers with transactions up to $2999.99 daily
  • Record customer information
  • Record transaction information
  • Retain customer and transaction data for 5 years from the date of transaction
Requirements for customers with transactions of $3000.00 or more daily
  • Record customer and transaction information
  • Verify the customer information including recording ID
  • Ask the sender to provide certain information about their transaction, such as proof of the origin of funds or details abou thow the money will be used
  • Retain customer and transaction data for 5 years from the date of transaction
Currency Transaction Reports (CTR)
  • Transactions totaling over $10,000.00 in the same business day require that Envios 22-24 file a CTR to the Treasury. The process for filing a CTR is as follows:
  1. Verify and record customer ID
  2. Record customer transaction information
  3. Make a copy of the completed CTR
  4. Send the original CTR to the IRS
  5. Keep a copy of the CTR for 5 years from the date of filing the report or the date of the transaction, whichever happens later
Suspicious Activity Reports (SAR)
  • SARs must be filed within 30 days of discovering an event where transactions totaling $2000 or more are suspected to be related to illegal activity by the money service business.
  • SARs are most commonly filed when a money service business suspects that funds from illicit sources (typically derived from drug and arms trade, human trafficking, blackmail, embezzlement, bribery, stolen goods, forms of prostitution) are being placed, layered, or integrated into the economy in an attempt to launder money.

For more details on Bank Secrecy Act regulation that affects you as our client, FinCEN has published an easy to understand reference page here.

ENVIOS 22-24 AND COMPLIANCE WITH REGULATION

Envios 22-24 is subject to regulation by the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of Treasury, as a registered money transmitter in the United States. Envios 22-24, Inc (FINCEN MSB Registration Number: 31000085108492) maintains a full AML compliance program, ensures proper and regular training of staff, and meets or exceeds all regulatory requirements found in the Bank Secrecy Act and Patriot Act, including organizational, operational, and business process requirements (OFAC, KYC, SAR, CTR, limits and velocities, ongoing AML training, data retention, audits, executive reporting, and more). Operating out of Florida, Envios 22-24 is also required to register with Florida’s Office of Financial Regulation.  License details can be found here (Funds Transmitter License #: 20800044). Organizational structures within Envios 22-24 operate in a manner fully compliant with Sarbanes Oxley and other regulation requiring separation of duties, controls around technology, and thorough and complete testing of financial systems.

INNOVATION IN REGULATORY COMPLIANCE

Envios 22-24 prides itself on not only complying with regulation, but in building technologies that improve the safety and efficiency of compliance infrastructure. We are developing technologies that reduce and potentially eliminate many of the unfortunate side effects of some regulation, such as identity theft resulting from poor execution of data retention requirements.

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