Inside the MSB Industry: An Interview with Philip Laufman, Lead Consultant at ComplyCheck

At ComplyCheck, we know that behind every successful Money Services Business (MSB) is an owner juggling ever-changing regulations, demanding BSA/AML compliance, and the everyday realities of running a check-cashing operation. To get an inside look at what really matters to MSB owners right now, our editorial staff sat down with Philip Laufman, lead consultant for ComplyCheck and a true expert with years of hands-on experience both as an operator and a compliance consultant. In this candid interview, Philip shares his real-world insights, practical advice, and predictions for the future of MSBs—covering everything from suspicious activity monitoring to navigating tough MSB banking relationships.

ComplyCheck Editorial Staff (CC):

Philip, thanks for joining us. To start, can you share a bit about your journey into the MSB and check-cashing industry, and what drew you into specializing in BSA/AML compliance for Money Services Businesses?

Philip Laufman (PL):

Thanks for having me. My story with MSBs began in the late 1990’s. I started in banking. I was a Regional Vice President and Compliance Officer for a bank that dealt heavily with MSBs. I eventually left banking to own and operate a check-cashing business with Luis Valle-Lisboa, ComplyCheck’s other lead consultant. In those early days, I was quite comfortable with BSA and AML compliance but when it came to the state regulations, the learning curve was steep. My first state audit had me second-guessing every record I kept and every transaction I processed. If, as a former bank compliance professional, I had that reaction, then what did MSB owners with no BSA and AML experience feel? But that’s also what opened my eyes to how critical compliance is—not just for meeting regulatory requirements, but for actually protecting your business from real risks like fraud and money laundering. While state and federal regulations began to tighten, other MSB owners knew of my compliance background and came to us for assistance. Over time, I realized there were very few resources out there for MSB owners who wanted real-world, actionable compliance help. That’s what made me get into the compliance consulting arena and eventually inspired us to start ComplyCheck.

CC:
With your direct experience, what do you think MSB owners most misunderstand about BSA/AML compliance, and what are the most common pitfalls when it comes to check-cashing regulations?

PL:
The biggest misunderstanding is thinking that BSA/AML compliance is just about “paperwork.” Sure, the documentation is critical, but the real heart of compliance is understanding your risks and being able to detect suspicious activity before it becomes a problem. A lot of MSB owners focus only on the minimum requirements for state check-cashing regulations or CTR filings but miss the bigger picture—like having proper Customer Due Diligence (CDD) procedures or training their staff to spot red flags. The other pitfall is letting files get out of date, especially with things like business licenses or customer identification. All it takes is one surprise audit for those gaps to become very costly.

CC:
There’s a lot of anxiety out there right now about MSB banking relationships. What advice do you have for check-cashing businesses who are worried about being de-risked by their bank, or struggling to find reliable MSB-friendly banking partners?

PL:
It’s probably the most common concern I hear. Banks are still wary of MSBs because of perceived risks around anti-money laundering compliance and suspicious activity reporting. My advice is to make your compliance program your best marketing tool—show your bank that you have strong controls, clean records, and a proactive approach to BSA compliance. Don’t wait until there’s a problem; keep your files organized, be transparent, and build a real relationship with your banker. Also, never rely on just one bank. Always have a backup plan. The reality is, you can do everything right and still face challenges, so being prepared is half the battle.

CC:
What’s the impact of recent regulatory changes, like FinCEN’s Geographic Targeting Orders, on everyday MSB compliance operations and check-cashing businesses in high-risk areas?

PL:
The FinCEN GTOs have completely changed the landscape, especially for MSBs and check-cashers near the Southwest border. Now, any transaction over $200 is in scope for reporting, which means compliance officers need to be on their toes, and systems need to be updated to flag and track these transactions. For many MSBs, this means reviewing their transaction monitoring protocols and ensuring staff are trained on the latest BSA requirements. It’s a heavy lift for small businesses, but not doing it puts your license and reputation at risk.

CC:
A lot of MSB owners are worried about suspicious activity monitoring and handling law enforcement requests. Can you walk us through how a robust compliance program can help MSBs manage these issues?

PL:
Absolutely. First, your suspicious activity monitoring has to go beyond just “checking the boxes.” You need to know your customers and their typical transaction patterns—this is where ongoing due diligence comes in. If you see something unusual, it’s not just about filing a SAR; it’s about investigating and documenting your steps. When law enforcement or regulators come knocking, being able to quickly pull up transaction records, CDD files, and your internal policies gives you credibility and often results in a faster, less painful process. In my experience, MSBs that take compliance seriously rarely get caught off guard—they’re prepared because it’s built into their daily routine.

CC:
How can MSB owners use technology to strengthen their AML compliance programs and make transaction monitoring more efficient?

PL:
The technology gap is a big issue, but it’s also the biggest opportunity. There are tools now that automate a lot of BSA compliance tasks, from customer onboarding to suspicious activity detection. Even smaller MSBs can benefit from digital recordkeeping and real-time alerts for transactions that need additional scrutiny. The key is choosing solutions that fit your operation and making sure your team actually uses them. We work with our clients to tailor these tools so that compliance isn’t a separate burden—it’s part of the workflow. In today’s world, having up-to-date, easily accessible records is a must for any check-cashing business that wants to stay ahead.

CC:
What are the most common mistakes you see when it comes to MSB staff training on anti-money laundering and suspicious activity reporting requirements?

PL:
The most common mistake is thinking of training as a one-time event or a formality. AML compliance is always evolving—staff need regular, practical training on how to spot suspicious activity and respond to law enforcement requests. I’ve seen too many businesses where employees can quote the policy manual but freeze when something real happens. The best programs include scenario-based training, ongoing refreshers, and clear escalation procedures. Staff are your first line of defense, so investing in their knowledge pays dividends.

CC:
Looking ahead, what do you see as the biggest regulatory and operational challenges facing MSBs and check-cashing businesses over the next few years?

PL:
I think the biggest challenge will be staying nimble as regulations keep evolving, especially around things like beneficial ownership, CDD, and transaction monitoring. Enforcement actions are getting more aggressive, and state regulators are collaborating more closely with federal agencies. There’s also more pressure for MSBs to adopt advanced technology, both to satisfy AML compliance requirements and to stay competitive. For smaller operators, keeping up can feel overwhelming. That’s why I always tell clients: focus on building a strong compliance foundation now, so you’re ready for whatever comes next.

CC:
Finally, for MSB owners who are worried about their compliance health or just want a second opinion, what would you say?

PL:
Don’t wait for a letter from your bank or a surprise exam to find out you have a problem. Proactive BSA/AML compliance isn’t just good business—it’s your best protection. At ComplyCheck, we offer practical, hands-on support because we’ve lived through the same challenges you face. Whether you need help with transaction monitoring, staff training, or just want a fresh set of eyes on your program, reach out. The first conversation is always free, and you’ll walk away with something useful—guaranteed.

CC:
Philip, thanks so much for sharing your experience and expertise. Your insight is invaluable to the MSB community.

PL:
Happy to help. Thanks for letting me share what we’re seeing on the front lines.