We have examiners on site. BSA examiner recommends us (the examiner will put that on the report) to add annual summary for the transaction activities (such as cash activity, ACH activity, wire) on annual review report.
Give you some background information about our bank:
We are a $250MM bank with 3 MSBs.
We monitor transaction monthly via Bankers Tool Box.
For MSB annual review, we have site visit, questionnaire, and review 3 months statements, make sure they register with FinCEN.
My thought process is: we already review their accounts monthly (because they hit alerts every month), is that necessary do that annually? Is that redundant?
Can anyone share what items they review on MSB annually?
Any information will be appreciated!
It all depends on the level of risk involved. In my opinion, what you perform sounds sufficient for an MSB agent (e.g. Western Union money order seller). However, if this were a higher risk MSB such as a check casher, you'd be better served with a more targeted account review, such as a comparison of check deposits to cash withdrawals to ensure they aren't using a separate cash source to exchange value for their checks.
Previous Thread
Index