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The U.S. enacted a new law named the Anti-Money Laundering Act of 2020 (AML Act) that includes provisions that have a long-arm jurisdiction and can impact foreign financial institutions. 

Banks offering account services to processors should assess the risks associated with these customers, by considering the following:

A risk factor when dealing with bulk cash shipments is knowing the true origination of the cash.

Without a general understanding of the BSA, the board of directors cannot adequately provide BSA/AML oversight; approve BSA/AML policies, procedures, and processes; or provide sufficient BSA/AML resources.

Thorough paper trail equals transparency

The bank’s AML compliance officer should have ready access to the bank’s board of directors.

An effective BSA compliance program would entail allowing a BSA compliance officer to have direct communication with the members of a the board of directors.

Consolidated information assists senior management and the board of directors in understanding and appropriately mitigating risks across the organization.

A mutual fund is a potential high risk customer type

As part of its internal controls, an organization should maintain appropriate arrangements to protect the confidentiality of a Suspicious Activity Report, including policies and procedures.