Anti-Money Laundering (AML)

Compliance Program Manual

AML Compliance Program Manual

BSA Requirement For MSBs

The Bank Secrecy Act (BSA), 31 CFR § 1022.210, requires that all MSBs establish and maintain an effective, written AML program. Reasonably designed to prevent the MSB from being used to facilitate money laundering and financing of terrorist activities. Must establish effective AML controls and procedures.

``````````

What Are The Requirements Of The AML Compliance Program Manual?

The program requirements must include monitoring policies and procedures, sufficient to allow the risks associated with the operation to be understood and explained. Under the rules of the Bank Secrecy Act (BSA), agents are responsible for developing the agency's policies, procedures, and internal controls. Each MSB is independently and fully responsible for implementing the appropriate AML program requirements. Consequently, the agent cannot avoid liability for failing to establish and maintain an effective AML program.

The BSA requires that the AML Compliance Program Manual must include at a minimum:

  • Incorporate policies, procedures, and internal controls reasonably designed to ensure compliance with the BSA and its implementing regulations.
  • Appoint the AML Compliance Officer to ensure daily compliance with the program and the BSA and its implementing regulations.
  • Provide appropriate education and training to staff on their responsibilities under the program. It should include training in detecting suspicious transactions to the extent that the money services business is required to report such transactions under the BSA.
  • Provide an Independent Review to monitor and maintain an appropriate program.

  • FinCEN works closely with its Delegate Examiners, the Small Business Division, the Internal Revenue Service (IRS), as well as State Regulators, to better coordinate the efforts of compliance and maximize resources. One area of focus is how effectively MSBs are currently monitoring their agencies. FinCEN expects that information will be available to demonstrate that it has effectively developed and implemented risk-based internal policies, procedures and controls to ensure continuous and adequate monitoring of the agency's activity.

    Source: https://fincen.gov/resources/statutes-regulations/guidance/

    Please complete the information below. Allow us 24-48 hours to contact you

    AML COMPLIANCE PROGRAM MANUAL SECTIONS

    Money Laundering
    Structuring
    Red Flags
    Bank Secrecy Act (BSA)
    Compliance Officer Designation and Duties
    Know Your Employees
    Money Wires
    Check Cashing
    Money Order
    Bill Payment
    Know Your Customers (KYC)
    Recordkeeping
    BSA Reporting
    Suspicious Activity Report (SAR)
    Currency Transaction Report (CTR)
    National Security Letter
    Employees' Training

    Please complete the information below. Allow us 24-48 hours to contact you

    • Independent Review

      Monitoring of the program's policies and procedures Anti-Money Laundering compliance of the trade and validate if it operates in accordance with the requirements of the Banking Stealth Law (BSA).

    • AML Compliance Program Manual

      The Bank Secrecy Act (BSA) requires all MSBs to establish and maintain a written AML program reasonably designed to avoid being used to facilitate money laundering and financing of terrorist activities.

    • Transactions Analysis

      Analysis of wires transactions made in business and its compliance with policies Regulatory Agencies.


    Please complete the information below. Allow us 24-48 hours to contact you

    Top