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.

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