In the November/December issue of ABA Bank Compliance, Jim Treacy addresses how banks can build an appropriate BSA/AML/OFAC Compliance Program. Jim covers performing an enterprise-wide BSA/AML/OFAC risk assessment, as well as developing a customer risk profile for each individual money service business (MSB). He also describes ongoing monitoring of MSB customers and MSB red flags that raise potential concerns. Although banking MSB customers comes with BSA/AML risks, these risks can be managed through a strong and effective BSA/AML/OFAC Program.
