Independent BSA/AML reviews, written AML programs, and staff training for check cashers, currency exchangers, and money transmitters — built by a CAMS-certified reviewer who knows exactly what your bank and your examiner need to see, because reviewing MSBs from the bank side was my job.
Every MSB must maintain an effective AML program with an independent review to monitor it (31 C.F.R. § 1022.210). But the pressure isn't only regulatory — your bank is required to perform due diligence on you, and a weak or missing independent review is one of the fastest ways to end up de-risked.
Banks routinely exit MSB relationships they can't document as low-risk. When your bank's BSA department asks for your latest independent review, risk assessment, and training records, the quality of those documents decides whether you stay banked.
The IRS examines MSBs for BSA compliance on FinCEN's behalf. Late CTRs, thin KYC files, and an out-of-date risk assessment become formal findings — and repeat findings escalate. A rigorous annual review catches them first.
Off-the-shelf manuals that don't match your actual services, thresholds, and systems are a red flag examiners and bankers spot immediately. Your program should describe what you really do — and prove that you do it.
Scaled to fit your operation, from a single-location check casher to a multi-state licensed money transmitter.
From $2,750 flat fee
The fourth pillar of your program, done right: a full review of your policies, four pillars, transaction testing (CTR, SAR, KYC, OFAC, logs), and a bank-ready report with risk-rated findings and practical fixes.
A written program that matches your actual business — not a template with your name pasted in. Built or refreshed to cover your services, thresholds, systems, and staff.
Role-based training your tellers and managers will actually use — with the documentation trail (materials, logs, attestations) your examiner and bank expect to see.
Banking MSBs and need boots on the ground? I perform on-site inspections and EDD support for bank BSA departments — the same reviews I ran in-house for MSB-banking institutions for over a decade.
Most MSB consultants have never worked inside a bank BSA department. I spent 14 years in them — including two California banks known for banking MSBs — reviewing high-risk MSB customers, writing the EDD procedures those reviews followed, and recommending which accounts to keep, restrict, or close.
That means when I review your program, I'm not guessing what your bank wants. I'm checking your program against the same criteria I used when the decision was mine.
More recently I've investigated financial crime for a Big-4 firm and led cryptocurrency investigations at a digital-asset MSB — so your review reflects how monitoring, typologies, and regulator expectations look today, not a decade ago.
Free call to confirm your services, locations, volumes, systems, and review period — so the engagement fits your size and risk, and you get a flat quote.
You get a clear checklist. I review your program, risk assessment, filings, and records, and interview key staff — on-site or remote.
Transaction testing across CTRs, SARs, KYC files, logs, and OFAC screening. Every exception documented; every finding risk-rated with a practical fix.
A bank-ready report with ratings, findings, and management responses — plus follow-up support so corrective actions actually close before your next exam.
Tell me a little about your business and what you need — an independent review, a program build, training, or bank-side inspection support. I'll reply within one business day.