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Sep4 - 21

Tips and Tricks for Policy and Procedure Development

If your business operations as a money transmitter or another money services business require BSA/AML (Bank Secrecy Act/anti-money laundering) compliance, part of this is having proper policies and procedures in place. These policies should be comprehensive and cover all the bases for any possible money laundering risks of your organization, and you should never take the development of your BSA/AML policies and procedures lightly. 

While you might not have the time and knowledge to design clear and effective policies and procedures, an experienced BSA/AML compliance consultant from Bates Group, can help with this process. 

Know the Five Pillars of BSA/AML Risk Management

The Financial Crimes Enforcement Network (FinCEN) sets out the five main pillars on which your entire BSA/AML compliance program should be based:

  • Having clear internal policies, procedures, and controls
  • The designation of an AML officer
  • Employee training on AML policies and procedures 
  • Independent testing and audits of the compliance program
  • Customer due diligence (CDD)

When you approach your policy and procedure development, you should keep in mind that effective policies are the foundational pillar of any compliance program. This is why you need to give your policies the focus and attention they deserve. 

There is No One-Size-Fits-All Compliance Program

It can be tempting to copy from another similar organization’s policies or model yours off one from a previous company. However, each program – including the specific policies and procedures – should be specifically tailored to your operations and business. 

Things to consider include:

  • Who is your usual customer base?
  • What types of transactions do you facilitate?
  • How many employees do you have, and what are their specific roles?
  • What are some key areas of risk for money laundering?

You need to examine each aspect of your business and, if an employee engages in transactions or any activities that require compliance, they need their own procedures tailored to their personal duties. Every role should have its own procedures and detailed training on those procedures. The process is more complex than setting a company-wide policy and moving forward. 

Seek Help from a Certified Compliance Professional

Perhaps the best tip for policy and procedure development is to outsource the task to a professional! The right consultant knows BSA/AML requirements, so you do not have to learn every intricacy. They have developed many policies and procedures for many other companies, and they know how to approach the matter in an efficient yet effective manner. This saves your company time and money now, as well as time and money later if you avoid BSA/AML issues. 

Let Our Policy and Compliance Specialists Help Your Business

If you need to develop policies and procedures for your company’s compliance program, you want the team of Bates Group helping you. We are all certified compliance specialists who assist a wide range of money services businesses across the United States. Contact us to discuss your company and how we might help as soon as possible. 




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