Preparing for an Independent Review of a Money Services Business’s (MSB) AML Program
Originally published October 21, 2022
https://www.batesgroup.com/news/preparing-for-an-independent-review-of-msb-aml-program
Money services businesses (“MSBs”) are required to conduct independent reviews to ensure their anti-money-laundering (“AML”) programs comply with Bank Secrecy Act (“BSA”) requirements. Under the BSA, MSBs must develop programs that identify and assess AML risks associated with their products, services, customers, and geographic locations and must take reasonable steps to manage them. Longstanding FinCEN guidance makes clear that the purpose of the reviews is to monitor the adequacy of these programs, especially in light of the recent expansion of BSA regulatory obligations under the Anti-Money Laundering Act of 2020. In this article, Bates offers tips to guide MSB firms in preparing for a review, including key review elements, timing, and selecting the right reviewer.
https://www.batesgroup.com/news/preparing-for-an-independent-review-of-msb-aml-program
Money services businesses (“MSBs”) are required to conduct independent reviews to ensure their anti-money-laundering (“AML”) programs comply with Bank Secrecy Act (“BSA”) requirements. Under the BSA, MSBs must develop programs that identify and assess AML risks associated with their products, services, customers, and geographic locations and must take reasonable steps to manage them. Longstanding FinCEN guidance makes clear that the purpose of the reviews is to monitor the adequacy of these programs, especially in light of the recent expansion of BSA regulatory obligations under the Anti-Money Laundering Act of 2020. In this article, Bates offers tips to guide MSB firms in preparing for a review, including key review elements, timing, and selecting the right reviewer.