All Things Need A Good "Once Over" From Time To Time – A Few BSA "Once Overs"

I cannot think of anything other than something disposable that does not need a "once over" from time to time.

Wise folks get a "once over" with their doctor in terms of an annual physical. Vehicles owners periodically get their mechanic to give their vehicle a "once over". Homeowners get their repair person to give their house a thorough "once over" at least annually, etc.

It is surprising just what a "once over" may reveal...gallstones you did not know you had, a leaking transmission fluid line, loose ductwork wasting energy with airflow going under your house, etc.

On the subject of banking, I could do a whole series of articles on "once overs". All of your risk assessments need the "once over" periodically due to changes in such things as product delivery, regulatory requirements, and events specific to your institution (a good reason for an easily adaptable system).

Relative to BSA related matters alone, the new Beneficial Ownership rules coming into effect May 11, 2018, require "once overs" at significant events such as BSA annual exemption reviews, product renewals, etc. Your MSB onsite reviews constitute a "once over" and may reveal such things as a private ATM you did not know was onsite thus requiring additional due diligence.

Even your initial customer due diligence as part of BSA is a "once over". Just one segment of that alone is often likely missed in terms of a "once over" at account opening – the MSB segment. It is more than asking "Are you an MSB?" and because neither the customer nor the person opening the account knows what that is a "No" block is checked and the process moves on.

Many factors must be considered, understood, explained and communicated between employee and customers including:

  • Check cashing greater than $1000 per day

  • Currency exchanges greater than $1000 per day

  • Sales of negotiable instruments greater than $1000 per day

  • Money transmitter of any amount

  • Seller of prepaid access

  • Provider of prepaid access (open loop and closed loop rules)

  • Money management services

  • Administrator or exchanger of virtual currency

Thus, on the subject of MSB's alone, you want to ensure the "once over" occurs at account opening, exemption reviews (just because you are reviewing the customer relationship at that time), and ongoing (such as during periodic onsite reviews). You also want to ensure the employee assigned to the "once over" is a qualified "doctor" to do it.

So, no matter the area, remember the "once overs".

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