By choosing Chesapeake Compliance Consultants, you will serviced by a Certified Anti-Money Laundering Specialist (CAMS) who understands both the regulatory obligations of your business and has experience in operating a Money Service Business.  Some businesses try to use internal staff but this can lead to questions of whether the review […]

The review can be conducted by anyone other than the Compliance Officer or anyone subordinate to the Compliance Officer.  However, the person conducting the review needs to have sufficient knowledge of the compliance obligations.  BSA regulation does not specify a frequency for a review.  The regulation requires the scope and […]

The review allows an independent party to assess both the adequacy of the policies and procedures used to mitigate financial crimes and the efficiency of the implementation of the policies and procedures.  The results of the review can provide an alert to deficiencies so they can be fixed.  In addition […]

Regulations only specify that training must be ‘periodic’ but the de facto standard is at least yearly.  Training should be specific to the job function of the employee and should be documented as to the materials used, the date provided, and the names of the employees trained.  Testing to confirm […]

Absolutely YES!  A Compliance Officer must have the necessary training, knowledge and experience, as well as the resources and time, to be able to implement and manage your compliance program.  An ignorant and ineffective Compliance Officer will result in a deficient compliance program.  A deficient compliance program can cause problems […]

No.  Your compliance manual must be customized to your business operation, address all the financial products and services you offer and cover all of your compliance obligations.  A money transmitter or other vendor is only providing generalized policies and procedures specific to their product/service.

The Bank Secrecy Act’s minimum requirements are known as the ‘four pillars’: Written policies and procedures to mitigate financial crimes Designation of a Compliance Officer Ongoing training to your employees Periodic independent review of your compliance program There are other federal regulatory obligations and you may have state regulations to […]

A report that is required by the Bank Secrecy Act to be filed for cash-in or cash-out currency transactions that exceed $10,000 for any one person in one business day.  Financial Institutions, and other businesses, must file the CTR to the Financial Crimes Enforcement Network (FinCEN) within 15 days of […]

In 1999, the Bank Secrecy Act was revised to designate certain Non-Bank Financial Institutions (NBFI) as ‘money services businesses’.  Check Cashers, Foreign Currency Exchangers, and issuers or sellers of money orders that conduct transactions for any of these services in excess of $1,000 for any one person in one business […]