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AML compliance for both traditional and non-traditional MSBs is complex and is not one size fits all. The ramifications behind key strategic and operational decisions can have a major impact on the company related to future cost, operations and compliance. The experience behind SOLV’s management team and partners has held leadership positions within financial institutions across the globe and we understand the challenges of developing adequate AML departments and programs. Having the responsibility as compliance officers, examiners, and investigators allows us to offer effective and sustainable solutions for all of our clients.
SOLV Compliance specializes in building successful AML compliance programs, ensuring that our clients have a clear understanding not only about what compliance is, but why they do it and how it fits their current needs in addition to providing above par service.
Per the BSA, Title 31 CFR § 1022.210, SOLV will assist in the following areas:
SOLV Compliance will assist in the “design, set-up, and implementation of the clients compliance programs and policies, taking into consideration the complex and unique laws across the US.” Furthermore, SOLV will incorporate internal controls reasonably designed to assure compliance with the BSA and its implementing regulations. See FinCEN Guidance.
Per the FinCEN guidance: The Bank Secrecy Act requires MSB’s to establish AML programs that include “an independent audit function to test programs.” This review should be conducted on a periodic basis however, the frequency should be determined based on the MSBs risk assessment which should consider the products offered, services, geographical location and the customers. “The key purpose of the independent review is to monitor the adequacy of the MSBs Anti-Money Laundering program.” The review will determine whether the business is operating in compliance with the requirements of the Bank Secrecy Act and of the business’ own policies and procedures.
Audits and reviews are time consuming. They demand your full attention and allow for minimal errors. We know because we’ve been there, elbows deep in both state and federal exams. With 12 years of auditing experience and client monitoring, we’ve seen it all from both the auditor and the businesses side of the fence, so we know what the reviewer is looking for and we get your business perspective regarding AML compliance. Whether you need someone to assist your audit team or be the team, manage the process or resolve complex AML/BSA compliance issues, SOLV can help.
In the event that you are required to obtain state licensing (Money Transmitter License) in order to operate your business, SOLV can assist you in both obtaining and maintaining your MTL. Every state has different requirements. For example, some will only accept applications through NMLS and some will not. It can be extremely costly, time consuming and complex when it comes to applying for a state license and every state is different. With SOLVs licensing experience, we are confident that we can ease this burden.
At SOLV Compliance, we take pride in our many years of AML/BSA experience. Whether you are new to the MSB industry or a seasoned company, SOLV can assist your compliance needs with providing you with correct, on the spot information, documentation and real-life service.
We are your place for education and development through Consulting. We examine what organizations are doing to stay relevant and competitive in this fast-paced, ever changing world of compliance. We strategize using the proper tools and resources to understand what your AML Program needs and ensure that proper BSA decisions are being made.