Introductory BSA AML Examiner School Manual Palm Springs 2019

MSB BSA Requirements

Bank Secrecy Act Compliance – there is no activity threshold for money transmitters.

BSA Requirements: • Develop an AML Program • Program must be in writing and risk based.

17

AML Program

At minimum, it should: • Incorporate Policies, Procedures and Internal Controls. • Designate an individual responsible for compliance. • Provide education and/or training to appropriate personnel. • Provide for an independent review to monitor and maintain an adequate program.

18