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Ask The Experts – Why Do Banks Keep Closing My MSB Account?

Ask The Experts – Why Do Banks Keep Closing My MSB Account?

Posted on: October 25th, 2021 by Julie

MSB bank account closures are avoidable. These are the most common reasons why a bank will close down an MSB account.

COMMON REASONS FOR MSB BANK CLOSURES

  • Outdated BSA/AML/OFAC Compliance Program
  • Deficient Independent Review
  • Insufficient Recordkeeping 
  • Improper CRT/SAR Filing

Outdated BSA/AML/OFAC Compliance Program 

The BSA/AML/OFAC Compliance Program must be risk-based, satisfy the five anti-money laundering (AML) pillars and cover current products and services.

Deficient Independent Review

An Independent Review needs to be reviewed by a qualified third party that includes an attorney, a CPA or a CAMS specialist. If any deficiencies are identified, it is important to create a plan to correct. 

Insufficient Recordkeeping 

Money services businesses should follow OFAC screening guidelines and store records securely for the appropriate amount of time.

Improper CRT/SAR filing

Failing to file CTRs and SARs or filing with incorrect information can lead to a bank shutting an MSB account down.

Although these are just some common issues, every bank has their own requirements and are federally regulated for MSB accounts. It is important to make sure you are following everything the bank requires. 

If you would like assistance with maintaining a healthy banking relationship, contact us.

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About the Author

Cesar Avalos, Sales Associate
Cesar Avalos
Sales Associate, Hablo Español

I enjoy building and customizing computers, playing video games and spending time with friends and family.

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