Financial institutions that offer check cashing, money transmitting and other money services need to obtain an MSB bank account in order to process these transactions. These money services are deemed as “high risk” and can make securing an MSB bank account on your own difficult.
Capital Compliance Experts works with both active Money Service Business (MSB) merchants and startup companies wanting to open an MSB account. Once our CAMs certified professionals analyze what paperwork you currently have to get a better understanding of your business, we will inform you of any documents that are either missing or not up to standard. Once those items are resolved we are able to work with our vast network of banks to find a good fit for your business. We will then guide you through the application process to ensure that you have all your documentation in order to ensure the likelihood of you getting an account.
Experience is what works most for a bank applicant. The more an applicant knows and the more prepared an applicant is, the better.
The last thing banks want are applicants who don’t have a clue what they are doing or worse, an applicant that has been doing MSB activity for years, don’t have written policies and procedures and never registered for the proper licenses.
A custom Anti-Money Laundering Program is a document that puts policies and procedures onto paper. Having a comprehensive program proves that you know your business well enough to have the essential policies and procedures in place to combat fraud and money laundering.
Now that you have your AML program, you and your employees need to have training. Certifying your employees means that they know the policies and procedures that are outlined within the AML program.
A Third Party Independent Review will be requested if the business has provided msb services in the previously at the business.
This review is to be performed by a qualified third party and is an in-depth audit of your AML Program. A CAMS certified representative is best suited to comb through your written policies and procedures because they know the MSB industry.
This will point out any deficiencies and gives you the opportunity to address those. Correcting deficiencies demonstrates that you are willing to fix issues, proactive and flexible.
Many factors are involved and reasons are mostly at the bank’s discretion.
However, there are automatic red flags where applicants can be declined automatically. Some of these red flags are applicants who have a criminal history, applicants dealing with or is a OFAC/SDN related individual, or being an agent of a company that the bank does not want a working relationship with.
A Risk Assessment from a third party provides insight into the level of risk associated with the MSB (low, medium or high). This assessment looks into the aforementioned, plus; geographic location, demographics of customers and much more.
Additionally, a Third Party Independent Review is the best way to uncover any deficiencies and/or red flags. If any deficiencies are revealed within your AML program, you will be presented with a plan to address any of those deficiencies.
Bank representatives always have concerns with the AML program.
It is imperative that the AML program is customized to ALL the activity within the MSB. Most of the time the AML program, of a respective merchant, is either obsolete or does not reflect all the MSB activity being conducted.
For instance, when Capital Compliance Experts is putting together an AML program for a client, we send out a detailed questionnaire that covers the scope of the MSB offerings
With this information, we can make the necessary updates or in many cases, write a new AML program that will not only cover the 5 pillars, but will also include all the policies, procedures, and MSB activity being conducted.
Another common concern that most banks have is the Independent Review not being detailed enough. You need to get someone who knows the industry. CAMS certified specialists know BSA requirements inside and out and are trained to pin-point any red flags/deficiencies within the AML program.
"After losing our bank account with Wells Fargo, Capital Compliance Experts created a new AML Compliance Program for us, recommended a change in licensing, performed a Third Party Independent Review, and consulted with our bank. When the dust cleared, we had a new banking relationship, and our business was saved. Capital Compliance Experts was instrumental in keeping our business open and we are thrilled with their service!"
owner, Aranki Holdings, LLC, Phoenix, AZ
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