Independent Review for Agents of MSBs

Federal guidance states that "a person that serves as an agent of another MSB is not required to register [with FinCEN]." Still, an agent is required to comply with all applicable Bank Secrecy / PATRIOT Act rules and regulations. Among these is the performance of an independent review. Such a review may be performed in whole or part by the owner or other key employee of an MSB agent. ImpactAML's Independent Review Workbook for MSB Agents is the perfect step-by-step guide for performing the review. Following the Workbook's simple steps will result in a comprehensive review that will stand up to your bank's or regulator's scrutiny. Even if you decide to outsource part of the review process, having completed the Workbook in advance will save considerable time and expense, as your auditor will have much of the work already done for him!