Insights: New MSB Examination Manual Challenges Regulators, Industry and Banks

By Carol R. Van Cleef and Maureen Sanders

The release of the long anticipated Bank Secrecy Act/Anti-Money Laundering Examination Manual for Money Services Businesses (MSB Manual) has left many regulators, money services business (MSB) and banks struggling to understand what the manual means for them. Uncertainty exists as to how the manual will affect the efforts of MSBs to meet recordkeeping and reporting obligations and prevent them from being used to facilitate money laundering and terrorist financing activities. Examiner Concerns. Examiners have a more detailed roadmap for examining MSBs and face the question of whether they have adequate resources to undertake examinations with the breadth and scope contemplated...