BSA/AML Independent Reviews

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BSA/AML Independent Reviews

The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) enforces the various requirements under the law for Money Services Businesses (MSBs). One requirement under the Bank Secrecy Act (BSA) is that each business in this industry must have clear anti-money laundering (AML) policies and programs in place. These programs must include Independent Reviews that take place to test the AML programs for BSA compliance. The frequency and scope of such reviews must be in line with the risk of the particular financial services offered by the business. 

These reviews are necessary to ensure that companies are operating in accordance with the BSA and that their AML policies are effective in minimizing money laundering risks. The designated Compliance Officer of the company may not conduct the review, nor can anyone who reports to the Compliance Officer. Many Money Services Businesses (MSBs) hire third-party professional reviewers and consultants to conduct these Independent Reviews to best prevent any compliance problems with FinCEN. 

If you are seeking assistance with your BSA/AML Independent Reviews, look no further than Bates Group LLC. Our consultants are CAMS, CAMS-Audit, CRCM, and CFRM certified, and some are former regulators who have specific insight into the review process and BSA/AML requirements. We advise Money Services Businesses on all types of compliance issues, and we are ready to assist your company.  

Our Independent Review Services 

A thorough Independent Review should seek out risks of noncompliance involving BSA/AML issues, as well as possible issues with the Office of Foreign Assets Control (OFAC) requirements. Our reviewers are highly trained in risk assessment when examining processes, policies, and procedures in light of BSA/AML requirements. 

Our reviews can encompass, but are not limited to:

  • Training Initiatives
  • Currency Transaction Reporting Exemptions
  • Currency Transaction Reporting (CTR)
  • Remote Deposit Capture
  • Cash Shipments
  • Funds Transfers Recordkeeping
  • Monetary Instrument Sales Recordkeeping
  • Additional Recordkeeping Requirements by the BSA
  • Verification of policies, procedures, and processes in light of the BSA record retention requirements
  • Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
  • Customer Identification Program (CIP) & Know Your Customer (KYC)
  • Possible Office of Foreign Assets Control (OFAC) Issues
  • Compliance with Beneficial Ownership and CDD Requirements
  • Compliance with USA PATRIOT Act sections 314(a) and 314(b)
  • FFIEC expanded procedures, if needed for your company
  • Suspicious Activity Monitoring and Reporting (SARs)
  • Review of State Examination Results

We have handled many complex Independent Reviews, including identifying concerns and advising Money Services Businesses regarding possible compliance issues. We understand the various regulatory requirements that apply to different companies, and we can ensure that you meet the requirements for your specific operations. Our professionals can determine the necessary frequency and scope of reviews needed for your business, as well as thoroughly document our findings in a manner compliant with the BSA. 

Speak with Our BSA/AML Independent Review Professionals Today

When it is time to meet BSA Independent Review requirements, you do not want to fall short. You want professionals with advanced CAMS-Audit and Certified Anti-Money Laundering Specialist certifications handling your reviews. To learn more about the services of Bates Group LLC, contact us today.

Development and enhancement of risk-based Compliance Programs
Consumer Protection Reviews and Gap Analysis
State Licensing
Money Transmitter License Acquisition and Maintenance

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