Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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9/26/2006 FinCEN Answers FAQs on MSB Independent Reviews

Independent reviews of the BSA/AML programs of money services businesses are to be risk-based, as is true of other covered financial institutions, and this means that the frequency of the independent testing will depend on an MSB’s risk assessment. FinCEN concedes that for some MSBs, the review need not even be annual, though for others an annual review might not be enough. If deficiencies are uncovered in a review, or in a government examination, another review might have to be scheduled soon after to verify that corrective actions have been taken. The review must be independent, but need not be conducted by a certified public accountant or a third-party consultant. An in-house reviewer can be used, provided he or she does not report to the designated AML compliance officer. Other aspects of MSB AML programs will be discussed in the December issue of the Monitor.

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