Money Service Businesses

I have a question regarding Money Service Businesses.

We have about 5 money service business customers. Most are small convenience stores. In our review of these accounts, we keep a copy of the MSB Registration to show they are current in this area. We do not have a copy of the MSB's BSA Policy. I would guess that they probably do not have one because they are a small business and do not know how to develop one. Are we as the bank required to make them as a BSA Policy or just show documentation that the should have one.

We are getting ready to have an examination from our state regulators and want to know how to answer to them if they ask.

Thanks

We explain to them that they should have an AML Policy and a designated AML person.
We give them the msb.gov website for them to learn the requirements.
We do not give any guidance on the actual policy or review anything they do.
We have them sign a certificate that states they have these requirements in place.

What kind of letter do you use for them to certify that the requirements are in place.

Just one that I made up.

I, ___________________________, on behalf of XYZ INC, certify that this entity has adopted an anti-money laundering compliance program.

Furthermore, I certify that XYZ INC will comply with all of the reporting and recordkeeping requirements imposed by the Bank Secrecy Act, the USA Patriot Act, and any other applicable anti-money laundering laws or regulations.

I understand that the official website for obtaining information is: www.msb.gov.