Anti-Money Laundering / Bank Secrecy Act / USA PATRIOT Act

Creating a Compliance Manual

Neither auditors nor banks will accept anything less than a thorough, tailored manual containing detailed procedures for conducting Bank Secrecy Act (BSA) related transactions, training employees, providing for independent audits, monitoring the compliance program, and retaining BSA related documentation.
Let USASI assist in the creation of your compliance program. From corporate resolutions adopting the compliance program to a record retention system, we can help get your compliance program on the right track

Training Employees

Whether we’ve helped you establish your program, or you took that initial step yourself, we can help train your employees. Our fully-tailored Employee Compliance Handbook contains not only background information on the Bank Secrecy Act, USA PATRIOT Act, Money Laundering Control Act, and other anti-money laundering laws and regulations, but also, and more importantly, how your employees are going to help the company remain in compliance with those laws and regulations. We can perform the training for you, or help you create your own in-house training program; either way, you will be sure to have an effective, affordable, customized solution to meet your training needs. [Note: Although not required by law, banks, government auditors, and wire transfer companies alike have requested that training be conducted annually.]

Auditing a Compliance Program

Independent audits should be done by an individual who is not involved with the day-to-day operations of the compliance program and who is knowledgeable about anti-money laundering requirements. U.S. Advisory Services can provide a thorough, unbiased review of your compliance program. Unlike government auditors, we highlight both strengths and weaknesses in our follow-up report, and provide [detailed] suggestions for improvement. If you’d prefer to keep it in-house, we can provide training on how to conduct such an audit, or even create audit documentation anyone can use to complete a review of your program. [Note: Although not required by law, banks, government auditors, and wire transfer companies alike have requested that audits be conducted annually.]

Maintaining a Compliance Program

The Compliance Officer is responsible for making sure the day-to-day work is completed. At USASI, we realize that compliance, more often than not, is one of numerous responsibilities the Compliance Officer juggles. That’s why USASI helps maintain compliance programs for clients nationwide. This maintenance includes [any or all of] the following:

• filing Currency Transaction Reports (CTRs)
• filing Suspicious Activity Reports (SARs)
• [re]filing Money Services Business (MSB) registrations
• monitoring money order activity
• monitoring wire transfer activity
• monitoring check-cashing activity
• revising compliance manuals
• assisting with Internal Revenue Service (IRS) correspondence
• assisting with wire transfer company correspondence
• assisting with money order company correspondence
• assisting with bank correspondence
• providing general assistance (customer support) to store employees
• conducting on-site visits

Protection of Consumer Privacy / Gramm Leach Bliley Act

Creating a Compliance Manual

The Gramm Leah Bliley Act (GLBA) requires institutions that collect non-public personal information to retain that information in a secure fashion. Additionally, privacy notices must be distributed in the event that consumers’ information is released or sold (except as permitted by law). Similar to anti-money laundering requirements, a Compliance Officer must be designated and procedures for complying with this act must be documented. While this topic is often included in the same manual as anti-money laundering and Office of Foreign Assets Control compliance procedures, our staff would be happy to help you create a free-standing document focusing solely on protecting the privacy of your consumers.

Training Employees

You can’t protect the privacy of your consumers without the help of your employees. Employees must know what to do (and, perhaps more importantly, what not to do) with the information they collect.

More often than not, training on this topic occurs with anti-money laundering and Office of Foreign Assets Control requirements; our staff, however, can help you create a program designed specifically for training employees on how to protect your consumers’ privacy at your request.

Auditing a Compliance Program

We can assess the strengths and weaknesses, both material and digital, of your protection of consumer privacy compliance program. We will assure you have a Compliance Officer in place who administers sound procedures, and provide a written report of findings that, among other things, offers suggestions for improvement.


Office of Foreign Assets Control

Creating a Compliance Manual

After the September 11th, 2001 terrorist attacks, the Office of Foreign Assets Control (OFAC) issued a statement saying “MSBs can no longer ignore their OFAC compliance responsibilities”. As a financial institution in the United States, you are not allowed to complete a transaction with a consumer that appears on OFAC’s Specially Designated Nationals (SDN) list, regardless of the type or amount. Consequently, you must have procedures in place to confirm that you do not violate this requirement.

Traditionally, this topic is addressed in the same manual as anti-money laundering and protection of consumer privacy compliance procedures; if this is not the case, however, our staff would be happy to help you create a free-standing document focusing solely on meeting OFAC requirements.

Training Employees

To comply with OFAC requirements, the transaction(s) must be terminated before completion. Your employees are the only ones capable of determining that a consumer utilizing your services is on the SDN list and terminating the transaction before it is completed. Consequently, they must be trained on OFAC requirements, when and how to screen consumers, and what to do if there’s a match.

Even though our training programs normally cover anti-money laundering and protection of consumer privacy compliance as well, our staff is capable of creating a program designed specifically for training employees on how to comply with OFAC requirements.

Auditing a Compliance Program

Let us provide feedback regarding your OFAC compliance program. We will evaluate the current procedures, and make suggestions for improvement [if necessary].

Providing Software Recommendations

Many point-of-sales software systems come with the ability to check consumers against the SDN list. We can make software suggestions based on your needs to assist you with meeting OFAC requirements.