Adapting to the evolving regulatory landscape is crucial for maintaining a robust banking relationship. Amend your BSA/AML/OFAC Compliance Program to align with the dynamic needs of your business. To assist you in staying abreast of these changes, we present an updated checklist designed to keep your policies and procedures current for 2024.
Our team of Certified Anti-Money Laundering Specialists (CAMS) has meticulously curated this comprehensive list. Collaborating closely with bank examiners nationwide, they have taken into account the most recent rules and regulations to ensure the checklist reflects the latest compliance standards.
REGULATORY COMPLIANCE ITEMS TO UPDATE IN 2024:
Renew Permits & Licenses
- Check Casher Permit
- Business License
- Fictitious Business Name Statement
- FinCEN Registration
BSA/AML/OFAC
- Independent Review (conducted by a third party)
- Current Risk Assessment
- Gap Analysis
- Annual Employee Training – BSA/AML/OFAC
- New or Discontinued Money Services
- Changes in Ownership Structure
- Changes in Check Cashing Fees
- Updated Corporate Check Cashing Policies
- Changes to Service Providers
- Updated Agent Verification Letters
- Additional or Closed Business Locations
- Changes in Designated Compliance Officer or Compliance Team
- Changes to Policies & Procedures to Reflect Manual and/or Automated Transaction Monitoring Procedures
- Compliance with FinCEN’s Customer Due Diligence (CDD) Rule
- Addressing your deficiencies from your 2023 Independent Review
- Supply your bank with all requested documents
- Monitoring Logs
- Adhering to record-keeping requirements
CFPB Readiness
- CMS Independent Review
- Updated Collection Processes
- Changes in Ownership/Management Structure
- Annual training – Lender Specific
- Complaint & Vendor Management Processes
NYDFS
If you would like help updating your compliance program, we are happy to review your money services policies and procedures.
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