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#1166529 - 04/20/09 04:36 PM MSB Policy (For MSBs)
Sheldon Hendrix Offline
Diamond Poster
Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
South
Does anybody have a sample MSB BSA/AML Policy they could share? We have several customer's who are MSBs and they are looking for a policy to adopt.

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BSA/AML/CIP/OFAC Forum
#1166548 - 04/20/09 04:58 PM Re: MSB Policy (For MSBs) Sheldon Hendrix
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
I personally don't think that a bank should have a copy of a BSA policy of it's MSB customer; if it is deficient in any way the bank could be criticized by an examiner. We require independent examination reports from our MSB customers (who are not agents of WU, etc).

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#1166642 - 04/20/09 06:44 PM Re: MSB Policy (For MSBs) devsfan
Retread Offline
Power Poster
Retread
Joined: Oct 2003
Posts: 2,548
Southeast
If you are looking for sample policies, here is one place to find them. I don't think you suggested that you were going to request a copy. You just wanted to know where to find one. If they decide to use the sample, don't forget to tell them to fill in the appropriate responses. One of our customers sent us one just like they appear on the website.

http://www.eacompliance.com/
_________________________
Politicians are like diapers. They need to be changed often and for the same reason.

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#1167797 - 04/22/09 01:36 PM Re: MSB Policy (For MSBs) Retread
Sheldon Hendrix Offline
Diamond Poster
Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
South
Thanks, Retread. You are correct - I didn't want to "write" or "provide" them with a policy. We are just wanting to provide them with some direction. Several of our MSBs are mom & pop convenience stores who cash checks on the side. We have provided them with guidance, and would also like to help them know where to find other resources that can facilitate their compliance efforts.

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