Seamless Audit Assistance for Your MSB

Money Services Businesses (MSBs) are subject to several levels of examination. Federal reviews are typically conducted by the IRS under Title 31 to ensure compliance with the Bank Secrecy Act (BSA) and related AML obligations. FinCEN may also initiate targeted reviews focused on suspicious activity reporting and data integrity.

At the state level, agencies such as Florida’s Office of Financial Regulation (OFR) conduct periodic audits to confirm compliance with Chapter 560, Rule 69V-560, and licensing requirements. Each type of review examines how well your AML program operates in practice, including policies, monitoring processes, employee training, and recordkeeping systems.

The frequency of examinations depends on your risk profile, transaction volume, and past performance. On average, most MSBs undergo an audit every 18 to 36 months.

However, MSBs that handle higher-risk transactions, operate across multiple states, or have prior findings may be reviewed more often. Regulators may also conduct unannounced or special audits in response to consumer complaints, suspicious activity, or referrals from financial institutions.

Regulators focus on whether your AML/BSA program is not only written correctly but effectively implemented. They examine:

• Transaction monitoring and alert investigation records.
• CTR and SAR logs and filing accuracy.
• Employee training schedules and documentation.
• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) files.
• The completeness and consistency of your AML/BSA manual.

They also look for a clear link between your policies and actual business practices. For example, if your manual states you review transactions daily, you must be able to show those daily reviews occurred and were documented.

Examiners usually request a comprehensive package that includes:

• Your AML/BSA manual and risk assessment.
• The most recent independent review report.
• CTR and SAR filing records.
• FinCEN registration and renewal documentation.
• Corporate customer files and identification records.
• Employee training logs and course materials.
• Daily cash reconciliations and transaction logs.

Having these documents well-organized demonstrates a mature compliance culture and sets a professional tone for the audit from day one.

Common issues identified by regulators include:

• Outdated AML manuals that no longer match operations.
• Missing or incomplete corporate files.
• Poor-quality or untimely SAR narratives.
• CTRs filed late or with data errors.
• Missing documentation of employee training.
• Inconsistent or undocumented transaction reviews.

Most of these findings are preventable with consistent monitoring, periodic self-reviews, and prompt attention to regulatory updates.

A Title 31 examination, led by the IRS, focuses on federal AML obligations under the Bank Secrecy Act, including transaction reporting, CDD, and recordkeeping.

A state audit, such as one performed by the Florida OFR, focuses on licensing compliance, operational controls, and adherence to state-specific laws like Chapter 560. While there is overlap, state regulators often pay closer attention to customer file documentation, Workers’ Compensation verification, and check-cashing practices specific to Florida.

At the conclusion of an audit, regulators issue a written findings report outlining any deficiencies, observations, or best-practice recommendations. You are required to respond in writing within a specified timeframe, usually 30 to 45 days, detailing corrective actions taken or planned.

Unaddressed findings can escalate into enforcement actions, fines, or license restrictions. A well- documented response that shows prompt remediation is one of the most effective ways to maintain regulatory confidence.

Preparation should start long before examiners arrive. Conduct an internal review or mock audit at least annually, comparing your current AML program against regulatory guidance and recent findings.

Verify that your AML manual matches your day-to-day operations, confirm all filings are up to date, and ensure corporate files, training logs, and reconciliations are complete. Designating a single point of contact for the auditors also helps streamline communication and reduces confusion during the review process.

ComplyCheck assists clients at every stage of the audit cycle. Before the audit, our team reviews your AML documentation, verifies that policies align with current practices, and helps organize all required materials for submission. During the audit, we can liaise directly with regulators, clarify examiner questions, and help present information accurately.

Afterward, we provide written analysis and assist with corrective action plans to close out findings efficiently. This end-to-end support allows MSB owners to focus on operations while maintaining full confidence in their compliance standing.

Yes. ComplyCheck conducts full-scale mock audits modeled after IRS Title 31 and Florida OFR examination procedures. Our process mirrors the regulator’s approach, reviewing your AML program, corporate files, transaction monitoring, and documentation trail to identify potential weaknesses before they become official findings.

Clients who undergo mock audits gain a clear picture of their compliance posture, receive practical recommendations for improvement, and are significantly better prepared for real examinations. In many cases, these preemptive reviews have helped MSBs achieve clean audits and zero deficiencies during official exams.