Banks And Credit Unions

Banks:

Federally insured depository institutions are the linchpin of the U.S. financial system. From the smallest community banks to the largest and most complex banks, these institutions face intense regulatory scrutiny and increasing supervisory expectations, making compliance a top-of-mind concern for executives and boards.

Financial institutions are required to implement and update effective BSA/AML Compliance Programs to ensure that their customers are not facilitating money laundering or terrorist activities.

Gilbert Reese consultants have the experience to guide clients through regulatory expectations for Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) and consumer compliance challenges.

Our services for banks include:

• Review of your MSB portfolio to ensure your MSB clients are abiding by the regulatory requirements by having a robust compliance program.
• We risk-assess your policies and procedures for onboarding and maintaining relationships with MSBs
• Conducting Third-Party Independent Reviews for your BSA/AML compliance program.

Credit Unions:

Credit unions occupy an important and growing niche in financial services. Traditionally focused on consumer lending and services, many credit unions have expanded to include a broader array of offerings and customer base in money services businesses. The same issues that challenge banks regarding banking MSBs vis-a-vis mitigating heightened risks of money laundering posed by MSBs, also impact credit unions.

Gilbert Reese understands that money service businesses have been fighting an uphill battle to stay banked by mainstream banks, which makes credit unions an attractive prospect. We also understand that banking MSBs makes Credit Unions vulnerable to risks of money laundering for drug cartels and terrorists.

We offer our services to assist Credit Unions build sufficiently scaled internal controls and compliance programs that allow them to perform necessary due diligence on MSBs.

We work with your internal teams to develop policies and procedures that enable them to:

• Perform the required Customer Identification Program procedures.
• Confirm that Credit Union Members register with FinCen.
• Confirm that member MSBs comply with state or local licensing requirements.
• Confirm the member MSBs’ agent status.
• Conduct BSA/AML risk assessment to document the level of risk associated with the account and whether greater due diligence is necessary.