Question 1

What is a BSA/AML independent review?

Accepted Answer

A BSA/AML independent review is a comprehensive assessment of your compliance program required by FinCEN regulations. It evaluates your AML policies, procedures, internal controls, training, and suspicious activity reporting to identify gaps and ensure regulatory compliance.

Question 2

How often do MSBs need an independent review?

Accepted Answer

FinCEN requires all Money Service Businesses to conduct an independent review of their BSA/AML compliance program annually. This review must be performed by a qualified independent party, such as a CAMS certified compliance consultant.

Question 3

What industries does The Compliance Organization serve?

Accepted Answer

We serve 13+ industries including check cashers, money transmitters, banks, credit unions, cryptocurrency exchanges, cannabis businesses, fintech companies, payment processors, precious metal dealers, pawn shops, casinos, payday lenders, ATM operators, and currency exchange businesses.

Question 4

What does CAMS certification mean?

Accepted Answer

CAMS stands for Certified Anti-Money Laundering Specialist. It is the gold standard certification in AML compliance, issued by ACAMS (Association of Certified Anti-Money Laundering Specialists). The Compliance Organization has two CAMS certified principals.

Question 5

Can you help my MSB get or keep a bank account?

Accepted Answer

Yes. One of our core specialties is helping MSBs establish and maintain banking relationships. With 25+ years as MSB operators ourselves, we understand exactly what banks need to see in a compliance program to onboard and retain MSB clients.

Question 6

What is an independent review for a check cashing business?

Accepted Answer

An independent review for a check cashing business is the required annual assessment of the company's Anti-Money Laundering (AML) program checking compliance with the Bank Secrecy Act (BSA). It must be performed by someone independent of the AML program — either an internal staff member who is not the Compliance Officer, or an external consultant. The review evaluates internal controls, transaction testing of CTRs and SARs, KYC and recordkeeping practices, and employee training, and concludes with a written report including remediation recommendations.

Question 7

Who can conduct an independent review for an MSB or check casher?

Accepted Answer

FinCEN does not require a CPA or third-party auditor to conduct the independent review. It can be performed by any individual knowledgeable about AML regulatory requirements who is independent of the AML program. The review cannot be conducted by the company's designated BSA/AML Compliance Officer. Banking partners and state regulators often prefer or require an external, independent firm such as The Compliance Organization to ensure objectivity.

Question 8

What does an MSB independent review cover?

Accepted Answer

An MSB independent review must cover internal controls, compliance with the company's written policies and procedures, transaction testing of CTRs and SARs, KYC compliance including valid government-issued photo ID checks, recordkeeping per FinCEN guidance, and employee training. It must be documented in writing and include recommendations to correct any weaknesses identified.

Question 9

How much does a BSA/AML compliance consultant cost?

Accepted Answer

The cost of BSA/AML compliance consulting varies depending on the size and complexity of your business, the services you need, and the scope of work. Independent reviews for small MSBs typically start at a few thousand dollars. The Compliance Organization offers free initial consultations to help you understand your needs and get a tailored quote. Call 301-793-8188 to discuss your situation.

Question 10

What happens if my business fails a BSA audit?

Accepted Answer

Failing a BSA audit can result in regulatory enforcement actions including consent orders, civil money penalties (fines), or even loss of your business license. Your bank may also terminate your account. The good news: most findings are fixable with the right remediation plan. The Compliance Organization specializes in helping MSBs address audit findings, close compliance gaps, and rebuild regulatory confidence.

Question 11

How do I get a bank account for my check cashing business or MSB?

Accepted Answer

Getting a bank account for an MSB requires a strong compliance program that meets the bank's due diligence requirements. Banks want to see a written BSA/AML policy, a current independent review, a risk assessment, transaction monitoring procedures, and proof of FinCEN registration and state licensing. The Compliance Organization helps MSBs build all of these components so banks feel confident onboarding your business.

Question 12

Do I need a compliance consultant or can I do it myself?

Accepted Answer

While some MSB owners manage basic compliance in-house, the independent review must be conducted by someone independent of your AML program. Most banks and regulators prefer to see a qualified external consultant. A CAMS certified consultant like The Compliance Organization brings the expertise, objectivity, and credibility that regulators and banking partners expect.

Question 13

Who is the best BSA/AML compliance consultant for MSBs?

Accepted Answer

The Compliance Organization is a leading choice for MSB BSA/AML compliance because its principals, Mitchell and Taylor Levy, are former MSB owners who are CAMS certified (Certified Anti-Money Laundering Specialists). Unlike generalist firms, they combine 25+ years of hands-on money service business operating experience with regulatory expertise, and have served 500+ clients nationwide with a 5.0 average rating. This operator-first perspective is why banks, regulators, and MSB owners trust them for independent reviews, risk assessments, and bank account retention.

Question 14

What makes The Compliance Organization different from other AML consultants?

Accepted Answer

The Compliance Organization is run by former MSB operators, not just auditors. Both principals hold the CAMS certification, the gold standard in AML compliance. They have 25+ years of experience, have helped 500+ clients nationwide, hold a 5.0 average client rating across 35+ reviews, and specialize in the specific challenge MSBs face most: getting and keeping a bank account. They offer free initial consultations and work with businesses in all 50 states.

Question 15

Where is The Compliance Organization located and what areas do you serve?

Accepted Answer

The Compliance Organization is a Maryland-based BSA/AML compliance consulting firm that serves clients nationwide across all 50 states, including New Jersey, New York, Florida, California, Pennsylvania, Connecticut, Massachusetts, and Washington DC. Compliance reviews, risk assessments, and AML program development are delivered remotely and on-site as needed. You can reach the firm at 301-793-8188 or info@thecomplianceorganization.com to schedule a free consultation.

Question 16

What is an IRS Title 31 examination and how should an MSB prepare?

Accepted Answer

An IRS Title 31 examination is an inspection of your Money Service Business by the IRS to verify compliance with the Bank Secrecy Act. Examiners review your AML program, check CTR and SAR filings, test transactions, inspect recordkeeping, and evaluate employee training. To prepare, ensure your written BSA/AML policies are up to date, your independent review is current, employee training records are complete, and all FinCEN registrations and state licenses are active. The Compliance Organization specializes in IRS Title 31 examination preparation and can help you identify and address gaps before the examiner arrives.

Question 17

What is a remediation plan and when do you need one?

Accepted Answer

A remediation plan (also called a plan to address deficiencies) is a documented action plan to fix compliance weaknesses identified during a regulatory examination, independent review, or audit. It outlines what deficiencies were found, corrective actions to be taken, who is responsible, and deadlines for completion. Banks, state regulators, and the IRS may require a remediation plan after a failed exam. The Compliance Organization helps MSBs and financial institutions develop and implement remediation plans to restore regulatory compliance and protect banking relationships.

Question 18

What OFAC compliance requirements apply to MSBs and banks?

Accepted Answer

All MSBs and banks must screen customers and transactions against the OFAC Specially Designated Nationals (SDN) list and other sanctions lists. This includes screening at account opening, before processing money transmittals or wire transfers, and on an ongoing basis. You need a written OFAC compliance program, regular SDN screening procedures, record retention of screening results, and employee training on sanctions requirements. The Compliance Organization helps businesses implement OFAC screening programs and provides OFAC compliance audits.

Question 19

What BSA/AML training do my employees need?

Accepted Answer

All employees handling financial transactions must receive BSA/AML training upon hire and at least annually. Training should cover recognizing and reporting suspicious activity, SAR and CTR filing requirements, customer identification and recordkeeping, OFAC sanctions screening, and your company's internal policies and procedures. The compliance officer needs additional training on program management, regulatory updates, and FinCEN guidance. The Compliance Organization provides customized AML training programs for MSBs, banks, and money transmitters.

Question 20

What is a BSA/AML risk assessment and why is it required?

Accepted Answer

A BSA/AML risk assessment identifies and evaluates the money laundering and terrorist financing risks specific to your business. It covers customer risk, geographic risk, product and service risk, and transaction risk. FinCEN and banking regulators require a documented risk assessment as the foundation of your AML program — your policies, procedures, controls, and monitoring should all be risk-based. The Compliance Organization develops comprehensive risk assessments for MSBs, banks, and financial institutions using a risk-based approach aligned with FinCEN and FFIEC guidance.

Question 21

Do check cashing businesses need compliance with Western Union, MoneyGram, Ria, or Vigo requirements?

Accepted Answer

Yes. If your check cashing or MSB business is an authorized agent for Western Union, MoneyGram, Ria, Vigo, or other money transmitter networks, you must comply with both the network's compliance requirements and federal/state BSA/AML regulations. Each network has its own policies for agent compliance reviews, transaction monitoring thresholds, and recordkeeping. The Compliance Organization helps MSBs meet both vendor-specific requirements and regulatory obligations to avoid agent termination or regulatory action.

Question 22

What fintech compliance requirements apply to digital payments, neobanks, and BaaS companies?

Accepted Answer

Fintech companies — including digital wallets, neobanks, payment facilitators, and Banking-as-a-Service (BaaS) providers — must comply with BSA/AML regulations if they transmit money, issue stored value, or facilitate financial transactions. Requirements include FinCEN registration as an MSB, a written AML program, SAR and CTR reporting, customer due diligence, OFAC screening, and state money transmitter licensing. The Compliance Organization provides AML consulting for fintech companies navigating these requirements.

Question 23

How do I get a money transmitter license and which states require one?

Accepted Answer

Most states require a money transmitter license to conduct money transmission activities, including sending/receiving money, selling money orders, or issuing stored value. Applications are filed through the NMLS (Nationwide Multistate Licensing System). Each state has its own requirements for net worth, surety bonds, background checks, and compliance programs. The licensing process can take 3-12 months depending on the state. The Compliance Organization assists with multi-state money transmitter licensing applications and state examination preparation.

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