Summer’s Over: Why Now Is the Time to Get Your MSB Compliance Program Back on Track

Summer tends to move at a different pace. For many Money Services Businesses (MSBs), the past few months may have been a blur of vacations, short-staffed offices, and day-to-day operations taking priority over paperwork and compliance checklists. It happens more often than most owners would like to admit. Compliance programs often slip, not intentionally, but because other fires seemed more urgent.

Now, as fall approaches and the calendar barrels toward the final quarter of 2025, MSB operators face a critical question: Is your compliance program where it needs to be? If not, there’s still time to turn things around. Regulators, banks, and law enforcement aren’t going to cut you any slack because summer was busy. Compliance isn’t getting easier, and it certainly isn’t becoming less important. In fact, it’s the opposite.

The good news? With the right focus, you can use the final months of the year to strengthen your compliance program, shore up weaknesses, and position yourself to start 2026 in complete compliance.

Why Compliance Often Slips During the Summer

Ask almost any MSB owner or compliance officer, and they’ll admit the same thing: summer is a challenge for maintaining consistency. Staff members are out, customer volumes fluctuate, and managers often put off time-intensive tasks like updating corporate files, refreshing AML training, or reviewing suspicious activity monitoring reports.

But regulators don’t care whether your compliance officer was on vacation in July or if your office was short-staffed in August. They expect continuous monitoring and accurate recordkeeping. Delays in filing Currency Transaction Reports (CTRs), incomplete Suspicious Activity Report (SAR) investigations, or outdated Customer Due Diligence (CDD) files can all cause serious headaches once examiners come calling.

This is why many examiners look more closely at gaps during the summer months. They know businesses sometimes let things slide, and they want to see whether your program is strong enough to handle the change of pace.

The Risks of Letting Compliance Slide

Even a short period of neglect can put an MSB at risk. Regulators and banking partners expect to see consistent, documented, and proactive compliance practices throughout the year. When those expectations aren’t met, the consequences can pile up quickly:

• Regulatory fines and penalties: Lapses in CTR or SAR filings can cost thousands of dollars per violation.
• Banking relationship risk: Banks monitor the strength of your program. Weaknesses, especially patterns of late reporting, can push them to cut ties.
• Reputation damage: Once regulators or law enforcement view your business as careless, trust evaporates. That loss of confidence can linger for years.

Even if you’re never fined or shut down, running behind on compliance tasks creates stress and disruption. Staff end up scrambling to pull files together, reporting deadlines are missed, and your overall program becomes reactive rather than proactive.

Why Fall Is the Perfect Time to Reset

If you’ve let things slip, you’re not alone. But now is the moment to correct course. The final quarter of the year offers a natural opportunity to reassess and rebuild. Taking action now not only ensures you end 2025 in compliance but also sets the tone for 2026.

This is the time to:

• Catch up on corporate file updates and verify that all required documents are current.
• Conduct an internal risk assessment to make sure your business model, volume, and customer base are accurately reflected.
• Review transaction monitoring reports for structuring or suspicious activity that may have been overlooked.
• Confirm that AML training is up to date for all staff and properly documented.

Think of it as a fall cleaning for your compliance program. Just as businesses use the end of the year to review finances, staffing, and marketing plans, compliance deserves the same level of attention.

Compliance Isn’t Getting Easier

Some MSB owners hope the regulatory environment will lighten up over time. Unfortunately, the trend points in the opposite direction. Regulators are scrutinizing MSBs more closely than ever. New Geographic Targeting Orders (GTOs), enhanced expectations around suspicious activity reporting, and stricter enforcement of Title 31 requirements mean the spotlight is not going away.

FinCEN and state regulators are increasingly focused on whether MSBs are taking a truly risk-based approach. They expect to see documented processes, detailed records, and timely reports. They know which businesses consistently keep their programs in shape and which ones only scramble when an examination is announced.

If your compliance program has gaps, examiners will find them. If your records are sloppy, law enforcement will notice. And if your banking partner suspects you aren’t staying on top of your obligations, they may decide it’s not worth the risk to keep your account open.

How to Finish the Year Strong

The next four months are crucial. Here’s what MSBs should be prioritizing to get back on track:

1. Perform a compliance health check: Take a hard look at your compliance program and identify weak spots. Don’t wait until an examiner does it for you.
2. Update corporate customer files: Verify that you have all required documents, ownership information, and risk assessments on file and current.
3. Review CTR and SAR processes: Make sure reporting deadlines are met and that suspicious activity is being properly investigated and documented.
4. Refresh AML training: Staff should be retrained at least annually. If you haven’t done it yet in 2025, schedule it now.
5. Document everything: Examiners reward documentation. If it isn’t written down, it didn’t happen.

These aren’t optional steps, they’re the backbone of your compliance survival.

The Competitive Advantage of Strong Compliance

It’s easy to view compliance as nothing but a burden. But the truth is, businesses that treat compliance as an ongoing discipline often come out ahead. Strong compliance programs don’t just keep regulators happy; they also build trust with banks, customers, and business partners.

MSBs that can demonstrate consistent, proactive compliance are more likely to maintain stable banking relationships, attract new customers, and grow without fear of sudden shutdowns. In a competitive market, your compliance reputation is a key differentiator.

Don’t Wait Until 2026

The summer might be over, but you still have time. If you start now, you can close out 2025 with a compliance program that is not just “good enough” but strong enough to withstand any regulatory review. More importantly, you’ll be ready to start 2026 without the cloud of compliance uncertainty hanging over your head.

Compliance isn’t getting easier. It isn’t going away. And it certainly isn’t optional. The MSBs that succeed are the ones that recognize compliance as a core part of their business, not an afterthought.

So don’t wait. Use the momentum of the new season to reset, refocus, and rebuild. Because when it comes to compliance, tomorrow is always too late.