As President of Associated Risk Group, Ryan is responsible for corporate administration and the management of sales, marketing and business development. ARG is an affiliate of Associated Banc-Corp ($22 billion bank holding company) that provides compliance consulting to small and mid size financial institutions. Prior to joining ARG, Ryan was employed with the U.S. Secret Service and lived in the Washington DC metropolitan area. His banking career started at E*TRADE Bank where he assumed the role of Bank Secrecy Act and Anti-Money Laundering Officer. In 2003, Ryan was employed at Associated Banc-Corp in Green Bay Wisconsin as Vice President, BSA/AML Director. In that capacity, he was responsible for the bank's Anti-Money Laundering, Bank Secrecy Act and OFAC compliance programs. He conducted several training programs throughout the year specializing in CIP, Identity Theft, Risk Assessment, Detecting and Reporting Suspicious Activity.
Ryan is currently a board member of the ABA National Compliance School and actively participates in the ABA Money Laundering Issues Group. He was a speaker at the 2004 ABA Regulatory Compliance Conference in Chicago, frequently conducts web seminars for Money Laundering Alert and also a member of ACAMS.
In the answer given by Ryan Rasske on "AML Requirements Upon Identifying an MSB", he stated, "It is up to the bank to conduct the proper due diligence on their MSB customers and ensure they are complying with the law." We are in the process of determining what our responsibility is as a bank to ensure that our customers are complying with the law. What specifically do we need to be doing to be sure that we are using "proper due diligence"?
I work for a convience store which is registered as a MSB. Our banker told us we would need to write a policies and procedures. Could you help with a sample or example. Or would you know where I might find one? We currently cash checks and sell money orders.
I have some questions regarding exempting customers. When you are initially exempting a person, what kind of documentation should be put in a file for the auditor's review, and would I use the same documentation for the biennial review?
Could you tell me what the requirements, from the bank's perspective, are when we identify a money service business (MSB)? Would this eliminate the necessity to notify customers of limitation requirements on existing accounts? Could this make monitoring of any of the savings accounts possibly unnecessary? Could you continue to pay interest on this type of account? Or would this be considered a total violation of Reg. D?