Mitigating the hazards that MSBs bring to your bank
We ensure that servicing MSBs doesn't put your bank at excessive risk and that you're not inadvertently facilitating financial crimes.
Federal regulators are dead serious about the compliance hazards associated with money service businesses (MSBs).
So are we.
Though including MSBs in your customer base can provide a steady source of fee income, such relationships also mean accepting greater risk and jumping through more regulatory hoops to make certain you're complying with BSA/AML requirements and protecting your bank from financial crimes.
When you service MSBs, you need an experienced, meticulous BSA/AML expert to ensure that such clients aren't endangering your bank.
We're that expert.
Providing guidance about MSBs, helping you adapt to new rules, and ensuring that you're not unwittingly enabling financial crimes through your MSB work are routine parts of our practice.
Our first order of business is thoroughly assessing your appetite for risk to determine whether you even want MSBs in your client mix.
We also conduct a comprehensive BSA/AML/OFAC risk assessment to be sure that your program can accommodate the greater exposure that an MSB brings to your doorstep and identify policy and procedural changes you may need to make.
Our exhaustive vetting process includes:
- Developing custom questions to identify an MSB's activities, services, and the geographic areas it serves.
- Understanding transaction volume, dollar amounts of transactions, and whether an MSB moves money domestically or internationally.
- Reviewing an MSB's history of compliance, its approach to adhering to BSA/AML requirements, and the employee training it has in place.
Based on our findings, we recommend the number and types of MSBs that are safe to do business with, the ones that fit your risk tolerance, and strategies for monitoring clients' risky behavior.
In addition, we consider the time and personnel you must commit to the oversight of each MSB and ways to adapt your systems and procedures to guard against crimes like money laundering and terrorist financing.
Working with MSBs is never a one-and-done, and we're by your side every step of the way.
TCA offers A Better Way for you to vet and manage your MSB clients, control your risk, and understand how to respond to changing regulations.
Key deliverables include:
- Performing enhanced due diligence, confirming that you're not doing business with MSBs involved with financial crimes.
- Establishing comprehensive onboarding procedures that give you a deep look at how a prospective MSB operates and whether it drastically ups your risk.
- Ensuring that you've taken appropriate steps to identify and prevent illicit activity.
- Developing a monitoring strategy to identify and respond to an MSB's questionable behavior.
- Keeping you updated on evolving threats associated with financial crimes and changing regulations.
Money Servicess Businesses
SAR FAQs
On October 5, 2025, FinCEN, along with the other prudential regulators, published new Suspicious Activity Report FAQs. TCA – A Better Way!
FinCEN Updates Compliance Date for New Type of Special Measure
This is an update of our June 27 and July 11, 2025 articles with updated dates. TCA – A Better Way!
AML/CFT Policy and Procedure Checkup
FinCEN continues to make communication updates. This is a reminder to check your AML/CFT policies and procedures to make sure they contain the following recently updated contact information: TCA – A Better Way!
FinCEN Updates Compliance Date for New Type of Special Measure
This is an update of our June 27,. 2025 article with updated dates. TCA – A Better Way!
FinCEN Issues New Type of Special Measure
As part of a supplemental appropriations bill passed in September 2024, Congress enacted the FEND Off Fentanyl Act. Section 2313(a) granted the U.S. Treasury the authority to impose special measures against financial institutions suspected of funneling illegal proceeds derived from the illegal manufacture, transportation, and sale of fentanyl. TCA – A Better Way!
Focus on Fraud and Suspicious Activity Reporting
A big focus of conversations in the AML/CFT world recently has focused on the increase in fraud schemes as a mechanism to generate illicit funds which are then ultimately laundered. Financial institutions of all sizes are feeling the impact of fraud schemes targeting their customers and their bottom lines. TCA – A Better Way!
