FinCEN has levied a civil money penalty against Sarith Meas for violation of the registration and anti-money laundering requirements of the Bank Secrecy Act (BSA) and associated regulations issued pursuant to the BSA. Meas was fined $12,500 for the violations.

Full Settlement Agreement. Excerpts and summary below:

Meas acted as an independent money transmitter located in Maine operating out of Meas’s residence. Meas executed funds transfers for customers located in the United Stated. In a typical transaction, a customer provided Meas with cash, checks, or money orders, along with instructions to transmit funds to a specified beneficiary, and Meas deposited those funds into her U.S. deposit accounts. Once the funds cleared, Meas instructed U.S. financial institutions to wire transfer funds to designated financial institutions 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.

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 program. FinCEN determined that Meas was an unregistered money transmitter from January 2006 through October 2010, in violation of BSA registration requirements for money transmitters.

After considering the seriousness of the violations and the financial resources available to Meas, FinCEN has determined that the appropriate penalty in this matter is $12,500.