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Collecting Data From MSB Accounts

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Question: 
What information should we be obtaining from our existing MSB accounts concerning their policies and procedures, and how are we to know if they are in fact following their own procedures...and does it matter?
Answer: 

Even a casual read of the AmSouth or Riggs case will tell you that the effectiveness of your AML program matters. As for knowing what information you need to obtain and monitor, a simple search of our "CIP and BSA/Patriot Act Issues" forum for the past six months using keywords "+MSB +monitor" (without the quotes) will yield enough suggestions to keep you busy.

Woven into the Threads you find in this search you will see a reminder that your monitoring needs to apply to all high-AML-risk accounts, not just to MSBs. Special attention needs to be given to non-bank financial institutions such as check-cashers or sellers of money orders that don't meet the threshold definition ($1,000 cash on any one day with any one person) of MSB. The thing that's "magic" about a customer's meeting the MSB definition is that you'll have to ensure that it has satisfied the registration requirement and has policies and procedures designed to meet the requirements for recordkeeping and reporting requirements for which it is responsible.

First published on BankersOnline.com 2/7/05

First published on 02/07/2005

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