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Anti-Money Laundering Regulations for Money Services Businesses

Independent Review of Anti-Money Laundering Programs

As a money services business, it is essential to establish an anti-money laundering (AML) program with written policies and procedures. This includes an independent audit function to test programs, which does not necessarily require hiring a certified public accountant or outside consultant.

Key Requirements for the Independent Review

• The review should include testing of internal controls and transactional systems and procedures to identify problems and weaknesses.
• The reviewer should determine whether the business is operating in compliance with the Bank Secrecy Act and its own policies and procedures.
• The review should cover all AML program actions taken by or defined as part of the responsibility of the designated compliance officer.

Conducting the Independent Review

A money services business does not necessarily need to hire an outside auditor or consultant for the independent review. Instead, the review can be conducted by an officer, employee, or group of employees who do not report directly to the compliance officer.

Frequency and Scope of the Review

• The review should be conducted on a periodic basis, with the scope and frequency depending on the money services business’s risk assessment.
• More frequent review may be warranted if compliance problems are identified or the risk assessment changes.

Documentation Requirements

The person or persons responsible for conducting the review should document the scope of the review, procedures performed, transaction testing completed (if any), findings of the review, and recommendations to management for corrective actions (if any). All documentation should be made accessible to government examiners and law enforcement personnel who have authority to examine such documents.

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