You’ve Completed Your Examination… Now What? 7 Proven Steps to Improve Your MSB’s Compliance Program

For Money Services Businesses (MSBs), a regulatory examination can be a nerve-wracking experience. Whether the examination was conducted by federal regulators, state regulators, or your banking partner, the process is an in-depth review of your Anti-Money Laundering (AML) compliance program, customer due diligence (CDD) procedures, and overall risk management practices.

But here’s the thing—successfully completing an examination doesn’t mean your compliance journey is over. In fact, it’s just the beginning. The real value of an examination is in what you do next.

After the examination ends and the immediate relief wears off, a crucial question remains: How can you ensure your Money Services Business (MSB) is stronger, more resilient, and more compliant going forward? It begins with taking a careful and honest look at the examination results, identifying weaknesses, and turning feedback into actionable improvements.

Step 1: Carefully Review the Examination Findings

The first step is to thoroughly review the examination report. Even if your MSB received a favorable outcome, it is critical to take the time to understand the feedback provided. Carefully read the entire report, noting any written observations, recommendations, or findings. Even informal comments should be taken seriously, as they can reveal vulnerabilities that may become larger issues in the future.

Why This Matters: Understanding Examiner Feedback

Every comment, recommendation, or observation from an examiner provides insight into how regulators view your compliance program. Ignoring even minor comments can lead to bigger problems down the road. This is your chance to see your program through a regulator’s eyes.

Step 2: Conduct a Post-Examination Internal Review

A post-examination internal review is an essential next step. Gather your compliance team and walk through the examination findings together. Discuss the examiner's main focus areas, identify any questions you struggled to answer, and explore any concerns you have about your AML program that the examiner didn’t mention. This is a chance to turn the examination into a learning experience, where honest feedback can reveal blind spots you might otherwise overlook.

Why This Matters: Turning Feedback Into Learning

An internal review is your chance to move beyond passive compliance and actively strengthen your program. It also helps you build a compliance culture where your team learns from mistakes rather than fearing them.

Step 3: Address Identified Issues Immediately

Knowledge without action is useless. If the examination highlighted specific issues—whether minor or significant—take immediate steps to address them. Critical deficiencies should be corrected without delay, while minor issues should also be resolved to avoid becoming future problems. This might mean updating your AML compliance manual, improving customer due diligence (CDD) procedures, or enhancing your record retention policies.

Why This Matters: Protecting Your Business and Reputation

Taking quick action on examination findings shows regulators that your MSB is committed to compliance. It also reduces the risk of repeat findings, which can lead to harsher penalties or even license suspension in future exams.

Step 4: Strengthen Your Policies and Procedures

Your compliance manual is the backbone of your AML program, and it must reflect best practices. Use the examination results as a guide to identify gaps or outdated procedures. Make targeted updates to align your manual with regulatory expectations and ensure your team understands how to follow them.

Why This Matters: Building a Strong Compliance Foundation

A well-written, up-to-date compliance manual is not just a document—it’s a tool that protects your business. Regulators will judge your program by what’s written in your manual and how well your team follows it.

Step 5: Train Your Team

Training is another essential component of post-examination improvement. Use the examination results as a training opportunity for your staff. Conduct a session specifically focused on the issues identified in the examination, using real examples to drive home key points. Reinforce the importance of following procedures, maintaining accurate records, and asking questions when unsure. Your team is your first line of defense in maintaining compliance.

Why This Matters: Your Team is Your First Line of Defense

Even the best policies are useless if your team doesn’t understand or follow them. Effective training turns examination feedback into practical knowledge.

Step 6: Monitor and Document Corrective Actions

Monitoring and documenting corrective actions is equally important. Maintain a log of each issue identified in the examination, the corrective action taken, the date of completion, and the responsible person. This not only helps you keep track of improvements but also demonstrates to regulators that you take compliance seriously.

Why This Matters: Proving Continuous Compliance

Regulators expect you to document and track corrective actions. If they see that you are proactive and organized, it builds trust and reduces the risk of severe penalties in future exams.

Step 7: Consider an Independent Compliance Review

For MSBs seeking a deeper level of assurance, an independent compliance review is a powerful tool. An independent review provides an unbiased assessment of your compliance practices and can reveal hidden vulnerabilities you may have missed. At ComplyCheck, we offer thorough independent compliance reviews that not only identify gaps but also provide practical recommendations for improvement.

Why This Matters: Uncovering Hidden Weaknesses

An independent review provides a fresh, unbiased look at your compliance program. It is especially valuable because even experienced compliance officers can become “too close” to their own program, missing red flags that an outside expert can spot.

Conclusion: Continuous Improvement is Key

Ultimately, a successful examination is not just about passing—it’s about using the experience as a foundation for continuous improvement. At ComplyCheck, we help MSBs strengthen their compliance programs, train their teams, and prepare for future examinations. If you want to go beyond simply passing your next examination and truly improve your compliance program, we can help.

Let’s talk. 📧 Email us at requests@complycheck.co or visit www.complycheck.co to get started.