Third Party Independent Reviews

We understand that a strong relationship with your bank is crucial to your business. The Compliance Organization specializes in supporting money services businesses and banks in ensuring compliance with U.S. financial regulations, including the Bank Secrecy Act, the USA Patriot Act, OFAC, and more.  As experts in anti-money laundering compliance, TCO can help you complete your Third Party Independent Review and assist you in making sure your business is compliant with the USA Patriot Act. Our independent reviews for MSBs ensure compliance with state regulations appropriate with the business. Our independent reviews for banks follow the FFIEC BSA/AML Examination Guide’s core examination procedures. TCO is committed to completing your review within the deadline set by your bank or the IRS.

In order to make sure that our programs effectively perform as the independent audit function required by the Bank Secrecy Act, TCO follows a strict protocol that includes a designated, trained compliance officer, risk-based policies and controls, continuous staff training, and an independent review. All of our reviews include each of these components, plus documentation, implementation monitoring, and more. Our process involves information gathering, on-site interviews, and inspection of transaction records and activity. Once we’ve completed a review, you receive a written report documenting our findings, recommendations and general appraisal. Your written report will determine whether your business is effectively complying with the Bank Secrecy Act and other policies. Then, we can work together to address any deficiencies that we’ve identified in your review and determine actionable steps for resolution.

Risk Assessment

Financial institutions such as MSBs are required by the Bank Secrecy Act to assess their risks and then develop, implement, and manage policies, procedures, and controls. Some smaller businesses may be able to do this using a risk assessment toolkit. But higher-risk MSBs who have more extensive compliance responsibilities call for a more thorough analysis. TCO can help you pick the risk assessment format that’s right for you. In addition, we can assess your Office of Foreign Asset Control (OFAC) risk and help you determine any necessary mitigation.

BSA/AML Compliance Policies & Procedures

After evaluating your risks, The Compliance Organization can review your existing procedures or help your MSB create a document detailing the BSA/AML and OFAC policies, procedures, and controls as required by the Bank Secrecy Act.

Due Diligence

Any MSBs that employ agents or foreign counterparts to provide services and facilitate transactions are at higher risk and must perform due diligence before engaging in these relationships, plus ongoing monitoring. TCO can help navigate these requirements by performing site visits and reviews of potential partners, or complete a detailed review of your files to ensure you are meeting all compliance obligations.

Monthly BSA/AML Compliance Monitoring

TCO will conduct transaction monitoring each month, reviewing your company’s transactions to detect and document structured transactions and other potential BSA/AML violations. As necessary, TCO will provide you with details for filing/verifying SARs and CTRs each month, as well with a summary of findings serving as documentation of the transaction monitoring for your bank and audits.

Additional MSB Services