We are a small, rural bank with no large commercial customers such as WalMart, Target, Publix. Our MSBs are very small commercial customers.
How in depth should the review of a small MSB's AML documentation be - for instance, Mom & Pop convenience stores? Should we actually review their AML written policy, procedures, training, etc? What if they don't have documentation for us to review? CTRs on one small MSB customer are filed at a maximum of 6 per year. Our other small MSB customers have never had a CTR filed in the three years I've been with this bank.
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Semiretired. Working parttime at Historic Westville as a tour guide.