Money Service Businesses

In addition to meeting proscribed regulatory compliance requirements, Money Service Businesses (MSBs) are coming under increased scrutiny from their banking services providers. Stratis Advisory provides the market insight, operational compliance expertise and commercial banking experience MSBs need to proactively and cost-effectively manage compliance operations and infrastructure.

Founded by former compliance officers with MSB experience and AML/BSA experts, Stratis Advisory has a hands-on understanding of the operational compliance issues that can negatively impact banking relationships, business continuity, and federal and state AML/BSA examinations.

Stratis Advisory can help you:

  • Understand and navigate the changing landscape for regulatory compliance requirements
  • Develop critical organizational infrastructure for compliance
  • Implement a robust, BSA/AML/OFAC Compliance Program
  • Obtain critical BSA/AML/OFAC training as required under the BSA
  • Execute U.S. state money transmitter licensing applications directly with the state licensing department
  • Obtain surety bonds for state money transmitter licenses
  • Support your designated Compliance Officer in scaling operations and ensuring ongoing risk mitigation and management
  • Outsourced due diligence, investigations, and suspicious activity reporting
  • Transaction monitoring rule development and evaluation
  • Perform agent due diligence and risk assessments
  • Conduct a comprehensive independent test of your MSB to meet your BSA requirements and onboarding and due diligence requirements of banks
  • Serve as a trusted advisor with banking partners on managing banking relationships
  • Cost-effectively achieve the level of compliance you need to maintain banking and customer relationships
  • Provide pre-FinCEN/IRS MSB BSA/AML examination (also known as a Title 31 Exam) assessment
  • FinCEN/IRS MSB BSA/AML exam management
  • Managing corrective action remediation from Title 31 exam, independent test, and any other gaps in your BSA/AML/OFAC program

Contact us for more information

Engagement Profiles:

AML/BSA Program Review for Global Money Transmitter

Situation and Background: Global money remittance company sought independent assessment of its AML/BSA program.

Key Issues:

  • Firm sought independent assessment of its AML/BSA program to proactively understand any gaps in its operations.
  • On-site assessment needed to include AML/BSA compliance program, including legal, compliance, and operations.
  • Determine whether enhanced due diligence methods of partners mitigated associated AML/BSA risks.

Services:

  • Executed assessment, which included management reporting, due-diligence of its remittance clients, risk-scoring methodology, regulatory reporting, transaction monitoring, and the overall program effectiveness.
  • Presented on-site findings to CEO and executive management team.
  • Memorialized assessment in written report.

AML/BSA Transaction Monitoring Rule Assessment for MSB

Situation and Background: Bitcoin startup needed to establish risk-based transaction monitoring rules to monitor customer transactions for unusual or suspicious activity.

Key Issues:

  • Firm needed trusted advice in developing risk-based transaction monitoring rules to assist with identifying unusual or suspicious customer transactions.
  • Firm sought to document rule selection process as part of its AML/BSA program requirements.

Services:

  • Conducted an assessment of money laundering risks specific to the client’s geographic market and business model.
  • Recommended specific rules to monitor customers transactions to assist with identifying unusual or suspicious transactions.
  • Drafted report providing analysis of rule selection, rule description, and any gaps in monitoring that may need to be addressed.