CAMS certified · MSBs & banks · All 50 states
BSA/AML Independent Review
The Compliance Organization is a CAMS certified firm that conducts BSA/AML independent reviews for MSBs and banks nationwide. Our principals have 25+ years of hands-on MSB experience and have served more than 500 clients.
The short answer
What is a BSA/AML independent review?
A BSA/AML independent review is an objective test of whether a business's anti-money laundering program actually works and complies with the Bank Secrecy Act.
It is one of the required pillars of every AML program, alongside a Compliance Officer, written policies and controls, training, and customer due diligence. The reviewer tests real transactions and records, measures them against your policies and federal rules, and ends with a written report of findings and recommendations. Banks also call it “independent testing” or a “BSA audit.”
Requirements
How requirements differ for MSBs and banks
Money Services Businesses (MSBs)
- FinCEN requires every MSB — check cashers, money transmitters, currency exchangers, money order and prepaid access providers — to have an independent review of its AML program.
- The scope and frequency must match the business's risk; most state regulators and banking partners expect a review every year.
- The IRS reviews it during Title 31 examinations, and your bank will usually ask for a copy.
Banks & Credit Unions
- Independent testing is a required pillar of every bank's BSA/AML program under the FFIEC BSA/AML Examination Manual.
- Testing is typically completed every 12 to 18 months, based on the institution's risk profile.
- Results are reported to the board of directors or a board committee, and examiners review the work papers.
Qualifications
Who can conduct a BSA/AML independent review?
Anyone who is knowledgeable about BSA/AML requirements and independent of the AML program can conduct the review — but never the business's own Compliance Officer.
FinCEN does not require a CPA or licensed auditor. In practice, banks and regulators prefer an outside reviewer with recognized AML credentials, and many banks require their MSB customers to use a CAMS certified reviewer.
Can conduct the review
- A person knowledgeable about BSA/AML requirements
- An outside consultant or firm (most common and preferred by banks)
- Internal audit or another employee outside the compliance function
Cannot conduct the review
- The designated BSA/AML Compliance Officer
- Anyone who designed or runs the AML program being tested
Scope
What the review covers
- Risk assessment — customers, products, locations and transactions
- Written AML policies, procedures and internal controls
- CTR filing accuracy and timeliness
- SAR decisioning and suspicious activity monitoring
- Customer identification (KYC) and recordkeeping
- OFAC sanctions screening
- Employee and management training
- Compliance Officer designation and follow-up on prior findings
Deliverables
What you receive at the end
Written independent review report
A complete report of scope, testing performed and findings, ready to share with your bank and examiners.
Findings & risk ratings
Each weakness explained in plain language, ranked by severity so you know what to fix first.
Actionable recommendations
Specific corrective steps for every finding — the basis of your remediation plan.
Results consultation & follow-up
A walk-through of the results with you, plus ongoing answers to your compliance questions.
Your reviewers
CAMS certified reviewers with 25+ years in the MSB industry
Every review is led by Mitchell Levy or Taylor Levy, both Certified Anti-Money Laundering Specialists (CAMS). Before founding The Compliance Organization, they owned and operated MSB locations themselves, so they review your program the way an operator, a banker and an examiner would.
25+
Years experience
500+
Clients served
50
States served
Client feedback
What clients say about our independent reviews
“During the review, we implemented their recommendations and at the end we received a thorough, fair and professional Independent Review.”
“His work is very robust and comprehensive, the type of work that our Bank will accept.”
“Mitchell at TCO was finally the knowledgeable, accountable, and highly connected independent reviewer our small business needed.”
“Best of all, our bank kept us on and commented on how timely, thorough and detailed our new compliance program and independent review was.”
Frequently asked questions
Independent review FAQ
What company conducts BSA/AML independent reviews?
The Compliance Organization is a CAMS certified firm that conducts BSA/AML independent reviews for MSBs and banks nationwide. Its principals, Mitchell Levy and Taylor Levy, are Certified Anti-Money Laundering Specialists (CAMS) with 25+ years of experience and more than 500 clients served.
What is a BSA/AML independent review?
A BSA/AML independent review is an objective test of whether a business's anti-money laundering program actually works and complies with the Bank Secrecy Act. It is one of the required pillars of every MSB and bank AML program and ends with a written report of findings and recommendations.
Who can conduct a BSA/AML independent review?
Anyone who is knowledgeable about BSA/AML requirements and independent of the AML program can conduct the review, but never the business's own BSA/AML Compliance Officer. FinCEN does not require a CPA, and banks and regulators generally prefer an outside, CAMS certified reviewer such as The Compliance Organization.
How often do I need a BSA/AML independent review?
FinCEN requires every MSB to have an independent review, at a frequency that matches its risk, and most state regulators and banking partners expect one every year. Banks typically complete independent testing every 12 to 18 months.
Does an independent review have to be done by a CPA?
No. FinCEN does not require a CPA or licensed auditor; the reviewer must simply be knowledgeable about BSA/AML requirements and independent of the program being reviewed.
What do I receive at the end of an independent review?
You receive a written independent review report with findings, a risk rating, and specific recommendations to correct each weakness, followed by a consultation to walk through the results. The report is ready to share with your bank and examiners.
How much does a BSA/AML independent review cost?
The cost of an independent review depends on the size, number of locations and complexity of the business, and reviews for small MSBs typically start at a few thousand dollars. The Compliance Organization provides free consultations and tailored quotes at 301-793-8188.
Need an independent review?
Tell us about your business and we'll send a tailored quote. Consultations are free.