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- Outdated BSA/AML/OFAC Compliance Program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Outdated BSA/AML/OFAC Compliance Program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 (AML) pillars and cover current products and services.
Deficient Independent Review
An Independent Review needs to be reviewed by a qualified third party that includes an attorney, a CPA or a CAMS specialist. If any deficiencies are identified, it is important to create a plan to correct.
Insufficient Recordkeeping
Money services businesses should follow OFAC screening guidelines and store records securely for the appropriate amount of time.
Improper CRT/SAR filing
Failing to file CTRs and SARs or filing with incorrect information can lead to a bank shutting an MSB account down.
Although these are just some common issues, every bank has their own requirements and are federally regulated for MSB accounts. It is important to make sure you are following everything the bank requires.
If you would like assistance with maintaining a healthy banking relationship, contact us.
GOT A QUESTION OF YOUR OWN?
RECOMMENDED READING
10 Reasons You (MSBs and FSCs) are Being Discontinued or Declined by Your Bank
Tags: AML, Anti Money Laundering, BSA, BSA/AML Programs, Check Cashers, CTR, Currency Transaction Report, Independent Review, Money Services Business, MSB, OFAC, SAR, Suspicious Activity Report, Third Party Independent Reviews
