All money services businesses (MSBs) are required to designate a Compliance Officer as identified in the five key compliance pillars compiled by the Bank Secrecy Act (BSA). COMPLIANCE PILLARS: Designation of a compliance officer Development of internal policies procedures and controls Ongoing relevant training of employees Independent testing and review Beneficial ownership The classification of […]
Every bank has their own requirements for opening a Money Services Business (MSB) account. The first step to acquiring an MSB bank account is getting organized and completing an application. APPLICATION ITEMS When completing an MSB bank account application, it is important to gather the proper items. The application will typically ask for, but won’t […]
When deciding on if your employees need compliance training, there are a few things to consider. WHO NEEDS TRAINING It is generally considered an industry best practice to have any employee performing a money service transaction to have adequate and ongoing training. This includes any employee that cashes a third party check, conducts a money […]
MSB bank account closures are avoidable. These are the most common reasons why a bank will close down an MSB account. COMMON REASONS FOR MSB BANK CLOSURES Outdated BSA/AML/OFAC Compliance Program Deficient Independent Review Insufficient Recordkeeping Improper CRT/SAR Filing Outdated BSA/AML/OFAC Compliance Program The BSA/AML/OFAC Compliance Program must be risk-based, satisfy the five anti-money laundering […]
Most banks will request an Independent Review from their Money Services Business clients annually. Here is the reason why… Banks, just like check cashers, money transmitters and other MSBs, are audited frequently. However, banks are audited by government entities. GOVERNMENT ENTITIES AUDITING BANKS Office of the Comptroller of the Currency (OCC) Federal Deposit Insurance Corporation […]
