Introductory BSA/AML Examiner School, Atlanta, CA

Bank Exam procedures

• Review the financial institution’s most recent BSA/AML Risk Assessment to determine the risks posed by MSBs. • Review the financial institution’s BSA/AML Policies and Procedures, including Customer Identification Program, Customer Due Diligence, and Enhanced Due Diligence.

• Review risked-based monitoring program.

Bank Exam Procedures

• Determine if the customer is an MSB.

• If it is an MSB:

– Is it a principal? – Is it a branch or agent? – Is it an agent for more than one principal?

• Go to FinCEN’s website and use the “MSB Registrant Search” web page to verify registration.

• Registration must be renewed every two years.