Skip to content
GeoDataVision
Thread Options
#499565 - 02/15/06 09:13 PM MSB Annual Visits
LSmith Offline
Platinum Poster
LSmith
Joined: Dec 2002
Posts: 703
Is it a requirement that the bank must make an annual visit to an MSB? What about all High Risk Customers? I read something about this in an MSB Registration Fact Sheet

Return to Top
BSA/AML/CIP/OFAC Forum
#499566 - 02/16/06 12:51 AM Re: MSB Annual Visits
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
You should state in your policy what actions you will take for each risk group.
For MSBs I would do quarterly visits.
For cash intensive customers, - if they are your local Burger King etc., I would do an annual visit.
Hope that helps you.

Return to Top
#499567 - 02/17/06 07:45 PM Re: MSB Annual Visits
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
We require site visits only for our high risk customers. A customer providing MSB services may, or may not, be high risk depending on the nature and volume of MSB services provided.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#499568 - 02/21/06 09:33 PM Re: MSB Annual Visits
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
BrendaC, what would "the visit" look like? are you observing customer activity, check cashing activities?
Thanks.

Return to Top
#499569 - 02/22/06 02:56 PM Re: MSB Annual Visits
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Exactly. We are looking at the business to make sure that what we see is what we expect. Sometimes you find surprises in the most unlikely places. We have found restaurants that are now in the funds transfer business in the back office (no signage in place as required, we visited because of ACH activity noted in the account that we suspected was related to funds transfer services). We have found convenience stores that sell money orders when they clearly told us that they did not and we have identified small grocers that seemed to have inordinate amounts of cash for the number of customers we observed during our visits (timed for what would normally be peak hours-I like Thursdays at about 4:00 pm). So look for signage supporting services offered by the customer, activity volume and velocity commensurate with nature of business, and check cashing practices (are personnel trained to ID customers and adhere to any limits that may have been communicated to you by the owner).

I also cold call businesses, especially convenience stores, that indicate they do not offer any money services. It only takes a moment to call and inquire whether they sell money orders.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#499570 - 02/22/06 07:58 PM Re: MSB Annual Visits
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
Thanks BrendaC. This is very helpful.

Return to Top

Moderator:  Andy_Z