Risk Management for MSBs

Introduction- The Bank Secrecy Act (“BSA”) requires that every Money Services Businesses (“MSB”) implement a BSA/Anti-Money Laundering (“AML”) Compliance Program.  Risk assessments provide a clear view as to the organization’s policies and procedures. Failure to implement a comprehensive BSA/AML Compliance Program may result in significant fines and/or penalties by state and federal regulators. So, what…

The Antimonopoly Prosecutor in Chile sides with MSBs on Bank Account Closures

We thank our colleague Carlos Grossman, for the report out of Chile where the Antimonopoly Division of the National Economic Prosecutor Office (División Antimonopolios de la Fiscalía Nacional Económica – FNE)  reports the investigation that took place after an August 2015 complaint by a Forex Firm denouncing seven banks of denying the opening of a…

FROM DERISKING TO DETENTE

Key positive developments in banking for MSBs It’s been a bleak period for money transmitters over the past several years. The specter of derisking —that business-killing policy of many banks in the US and globally—may be disappearing. At least in the US where other entities are stepping up. Our colleagues in other parts of the…