US Financial Institutions including: Money Transmitters, Check Cashers, Dealers on Precious Metals, Foreign Currency Exchanger, among others financial institution are under the FinCEN mandatory frame of regulation. Each company in accordance with the services provided and where the services is provided need to understand and apply any FinCEN or State regulation in order to fulfill the mandatory frame from your primary law enforcement and FinCEN. Remember that if your company operate on a US State or Territory or is doing business with any US Company it is required to be in compliance with each and all applicable rules and regulations.
Following there is a timeline chart where you can find out how the BSA laws and regulations as well as FinCEN requirements has evolve since it’s begin at 1970 until the last applicable requirement on Customer Due Diligence and requirements Effective Date: July 11, 2016; and mandatory to compliance by May 11, 2018.
Source: FinCEN