Our CAMS experts have put together a comprehensive compliance checklist to help you stay on track and stay up-to-date with current BSA regulations.
Rules and regulations are constantly changing in the Money Services Business industry. It is your responsibility to update your BSA/AML/OFAC Compliance Program to reflect these changes and any other modifications in your money services at least annually.
REGULATORY COMPLIANCE ITEMS TO UPDATE IN 2021:
Renew Permits & Licenses
- Check Casher Permit
- Business License
- Fictitious Business Name Statement
- FinCEN Registration
BSA/AML/OFAC
- Independent Review
- Conducted by a third party
- Risk Assessment
- Current
- Gap Analysis
- Annual Employee Training – BSA/AML/OFAC
- New or Discontinued Money Services
- 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 2020 Independent Review
- Supply your Bank with All Requested Documents
- Monitoring Logs
- Adhering to Record Keeping Requirements
- Changes in Ownership or Corporate Structure
- Internal Monitoring
- Records Retention
- Law Enforcement/Government Requests
CFPB Readiness
- CMS Independent Review
- Updated Collection Processes
- Changes in Ownership/Management Structure
- Annual training Lender Specific
- Complaint & Vendor Management Processes
NY DFS
If you would like support in implementing this checklist into your compliance oversight, contact us.
info@CapitalComplianceExperts.com
(866) 922-4325
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