This ultimate regulatory compliance checklist will help any Money Services Business (MSB) stay up-to-date with current BSA guidelines.

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 2022:

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
• Updates or changes regarding technologies or software utilized
  • Examples: check cashing, OFAC screening, identification verification, etc.

CFPB Readiness

• CMS Independent Review
• Updated Collection Processes
• Changes in Ownership/Management Structure
• Annual training Lender Specific 
• Complaint & Vendor Management Processes

NY DFS

• Cybersecurity Regulation
• Part 504 Rule
• Transaction Monitoring

If you would like support in implementing this checklist into your compliance oversight, contact us. 

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