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
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How do I complete Part II (Amounts and Dates) on a continuing activity suspicious activity report (SAR) if the transaction took place on a single date? Do I include the investigation range from the previous filing?
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When dispositioning alerts from our automated BSA/AML monitoring system, how much information is enough?
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Welcome to TCA’s BSA Back to Basics article series! Each month, our BSA experts will explore a section of the FFIEC BSA/AML Exam Manual, analyze the regulatory requirements, and offer insights to common findings in exams and audits. We will share best practices to help your BSA program continue to evolve. The first section of …