If you are like most business owners, you probably have a lot on your plate. You may not have time to do everything yourself, so you hire outside help. When it comes to your website, is it important to you that the people who design and manage it are qualified? If so, the Independent Review Form can be a valuable resource. This form lets potential web professionals know that you take your website seriously and want to work with someone who knows their stuff. By completing the form, professionals can show they meet your standards and are qualified to work with you.
Here is the data in regards to the file you were seeking to fill out. It will show you how much time you will require to complete independent review form, exactly what fields you will have to fill in, and so forth.
| Question | Answer |
|---|---|
| Form Name | Independent Review Form |
| Form Length | 10 pages |
| Fillable? | No |
| Fillable fields | 0 |
| Avg. time to fill out | 2 min 30 sec |
| Other names | independent review form pdf, msb independent review sample, sample aml independent review, review money independent |
Section 4 : Independent Review
INDEPENDENT REVIEW
When you established your Compliance Program and with MoneyGram's approval, you indicated how often you would have an Independent Review of your AML Compliance Program.
In the event that you do not have your own Independent Review form, the following pages of this section contains an Independent Review template that you should have the reviewer use as a guide and complete accordingly.
As a reminder:
An Independent Review of your MSB is required by Federal AML Regulations.
The Independent Review will be conducted by a person or persons who are knowledgeable about the AML requirements that apply to MSBs.
The Agent's Independent Review cannot be conducted by your designated Compliance Officer, anyone that reports to your Compliance Officer, or any MoneyGram representative.
What do I do with the completed Independent Review Form?
Once the Independent Review Form has been completed and signed by the reviewer, please keep/file/store it with your Compliance related documents for at least 5 years.
Please make extra copies of the blank Independent Review Form and
do not use your last blank one.
INDEPENDENT REVIEW FORM
Independent Review Form Page 1
Please Complete ALL Parts, Questions, Blanks, and Fields
Note: The Independent Review cannot be conducted by your designated Compliance Officer, anyone that reports to your Compliance Officer, or any MoneyGram representative.
Business Name/Business DBA: |
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Business Street Address: |
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City: |
State: |
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Zip: |
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How many OTHER locations does this business |
* Note: Please provide addresses for other locations covered by this review on |
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operate that processes MoneyGram services?* |
Page 9 of this Independent Review Form. |
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Part 1: MONEY SERVICES BUSINESS (MSB) REGISTRATION (Only Check One)
MSB Registration is NOT required at the time of this review because the Business DOES NOT conduct a money service business on its own behalf and is covered by the MoneyGram MSB Registration.
MSB Registration IS required at the time of this review because the Business DOES conduct a money service business on its own behalf and IS registered as a MSB with the US Department of Treasury. A copy of the registration IS kept in the Business AML Files.
Part 2: RISK ASSESSMENT
MSBs are often targeted by money launderers or other criminals to help them hide or disguise the nature, location, source, ownership or control of illegally obtained money. The risk of this occurring increases based on the location of the Business, the number and types of financial services offered and/or the number of providers offered. Offering multiple products and/or services increases a money launderer or other criminal's ability to structure transactions to avoid detection and recordkeeping requirements.
If more than one (1) product or service is offered, the Independent Reviewer should review the Business' Compliance Program with more
Location Risk
Law enforcement agencies and government regulators have identified areas that are at higher risk for money laundering, related financial crimes, and drug and human trafficking. The appropriate websites are listed to help determine the correct response to the following questions:
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No |
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Is the Business located in an area at high risk for money laundering or related financial crimes? |
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http://www.fincen.gov (Search site for high risk areas for money laundering) |
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No |
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Is the Business located in an area at high risk for drug trafficking? |
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http://www.whitehouse.gov (Search site for Drug Trafficking areas) |
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No |
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Does the Business transfers funds to |
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http://www.treasury.gov/ (Search site for OFAC sanctions) |
Product Risk
Which products or services below does the Business offer: (Check all that apply)
Money/Wire Transfers |
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Money Orders |
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Stored Value Cards |
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Currency Exchange |
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Check Cashing |
Service Risk
Being an Agent for more than one MSB provider/competitor of money services makes it easier for a money launderer or other criminal to structure transactions to avoid detection and recordkeeping requirements.
Yes |
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No |
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Is the Business an Agent for more than one MSB provider? |
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If "Yes", please list all Business' MSB Providers:
Part 3: COMPLIANCE PROGRAM
Independent Review Form Page 2
Compliance Officer
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No |
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Has the Business Designated/Named a Compliance Officer? |
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Name of the Business Compliance Officer: |
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No |
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Does the Compliance Officer fully understand and complete the responsibilities of this position? |
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Yes |
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Briefly describe, in the space below, the responsibilities of the Compliance Officer and explain how the Independent Reviewer is certain the Compliance Officer understands and complete the responsibilities of this position:
Compliance Program
Yes No
Yes No
Has the Business adopted a written Compliance Program?
Does the adopted Compliance Program includes written policies, procedures and internal controls designed to comply with the requirements of the Bank Secrecy Act including:
Customer identification
Recordkeeping and retention requirements Response to law enforcement requests for information
Briefly describe, in the space below, how the Compliance Program was verified by the reviewer:
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No |
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Does the Compliance Program include limits specific to the Business, such as a maximum send amount, a |
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maximum receive amount or a maximum amount of money orders that may be purchased? |
Briefly describe, in the space below, how these limits are monitored and enforced:
Part 4: EMPLOYEE TRAINING
Independent Review Form Page 3
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
If a "No" was checked for any question above, please use the space below to explain why:
Training Frequency Schedule
Please indicate below the schedule the Business implements for employee AML Compliance related training: (Check all that apply)
Every Month |
Every 6 months |
Once a Year |
As Necessary |
Briefly describe, in the space below, the training material and content:
Briefly describe, in the space below, how the employee training process/content was verified by the reviewer:
Part 5: MSB TRANSACTION PROCESSES
Independent Review Form Page 4
Customer Identification
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No |
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Is a valid, government issued, photo I.D. recorded for money order sales of $3,000 or more? |
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Yes |
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No |
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Is a valid, government issued, photo I.D. recorded for money transfer transactions of $900 or more? |
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Yes |
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No |
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Does the Compliance Officer (or their designee) periodically review the Money Order logs, the Send/Receive |
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forms, and/or the Form Free receipts to ensure that the Customer I.D. policy and procedures are being |
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followed? |
Briefly describe, in the space below, how the customer I.D. process was verified by the reviewer:
Money Order Processing
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No |
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Are all money order transactions of $3,000 or more recorded on a Money Order Log? |
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No |
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Does the Compliance Officer (or their designee) review daily activity to identify money order transactions that |
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may require a money order log to be completed? |
How often are money order logs reviewed to determine if CTRs and/or SARs should have been
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Every Day |
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Every Week |
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Every Month |
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Other (Explain Below) |
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No |
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Are completed money order logs stored for a minimum of 5 years? |
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Money Transfers Processing
Yes No Are money transfer send/receive forms or form free receipts accurately completed for transfers of $3,000 or more?
Yes |
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No |
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Does the Compliance Officer (or their designee) review money transfer send/receive forms or form free |
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receipts for accuracy and completeness? |
How often are money transfer send/receive forms or form free receipts reviewed to determine if CTRs and/or SARs should have been
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Every Day |
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Every Week |
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Every Month |
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Other (Explain Below) |
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Yes |
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No |
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Are money transfer send/receive forms or form free receipts for transfers of $3,000 or more stored for a |
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minimum of 5 years? |
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Briefly describe, in the space below, how the money order/transfer processes was verified by the reviewer:
If a "No" or "Other" was checked for any question above, please use the space below to explain why:
Part 6:
Independent Review Form Page 5
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No |
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Does the Compliance Officer (or their designee) review all transaction activity to look for structuring and |
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other suspicious patterns to ensure that SARs are being |
Transaction activity is reviewed:
Every Day
Yes No
Yes No Yes No
Every Week |
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Every Month |
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Other (Explain Below) |
Are there blank
Are SARs accurately completed and timely
Are copies of SARs that were
Yes No Does the Compliance Officer (or their designee) review all transaction activity to identify those transactions that, either individually or combined, may require a CTR to be
Transaction activity is reviewed:
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Every Day |
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Every Week |
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Every Month |
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Other (Explain Below) |
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No |
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Are there blank |
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from transactions requiring a CTR? Note: CTRs are |
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Are CTRs accurately completed and timely |
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No |
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Are copies of CTRs that were |
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Yes |
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No |
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Briefly describe, in the space below, how the SAR/CTR
If a "No" or "Other" was checked for any question above, please use the space below to explain why:
Part 7:
Yes No
Independent Review Form Page 6
Yes No
Yes No
Yes No
Yes No
Briefly describe, in the space below, how the
If a "No" was checked for any question above, please use the space below to explain why:
Part 8: INDEPENDENT REVIEW
Yes No Are Independent Reviews regularly conducted on the Business to monitor and maintain a required compliance program?
How often is an Independent Review conducted?
Every Six Months |
Every Year |
Other (Explain Below) |
Briefly describe, in the space below, how the Independent Review process was verified by the reviewer:
If a "No" or "Other" was checked for any question above, please use the space below to explain why:
Part 9: BUSINESS DATA and RECORDS ANALYSIS
It is critical that the Business being reviewed is meeting reporting and recordkeeping requirements. reviewer conducts an analysis or test on a sample of random completed transactions from the past. are detailed below.
Independent Review Form Page 7
It is recommended that the Guidelines for this analysis
Yes No
Briefly describe, in the space below, the results of the business data and records analysis:
Business Data and Records Analysis Guidelines
1.Money transfers of $900 and above must include the customer's:
Name
Current residential address
Phone number
Type of ID provided, the ID number and the ID issuer
2.Money transfers of $3,000 and above must include the customer's:
Name
Current residential address
Phone number
Type of ID provided, the ID number and the ID issuer
Social Security number (SSN) or Tax ID Number (TIN), if the customer is a citizen or authorized resident in the U.S. A SSN or TIN is unnecessary if the customer lives and works outside of the U.S. and presents a passport or other applicable photo ID issued by a foreign government.
Date of birth (DOB)
Specific occupation
Signature
3.Multiple money order cash purchases made by the same person in one business day must be aggregated, or added together, and treated as a single purchase, even if purchased at different times during the day. If the same consumer purchases $3,000 or more in money orders, using cash, in the same day, the following consumer transaction information must be recorded on a Money Order Log BEFORE completing the transaction(s):
Name
Current residential address
Phone number
Type of ID provided, the ID number and the ID issuer
Social Security number (SSN) or Tax ID Number (TIN), if the customer is a citizen or authorized resident in the U.S. A SSN or TIN is unnecessary if the customer lives and works outside of the U.S. and presents a passport or other applicable photo ID issued by a foreign government.
Date of birth (DOB)
Specific occupation
Signature
4.Aggregated transaction activity should be reviewed to determine if SARs or CTRs were required to be
Independent Review Form Page 8
Acknowledgement of Independent Review Completion
I certify an independent review of the compliance program belonging to the Business listed below has been completed.
Business Name/Business DBA:
Among other things, this review focused on the requirements of the USA PATRIOT Act and the Bank Secrecy Act. The results of this review show that the Business'
Acceptable |
Acceptable: Requires Enhancements Detailed Below |
Unacceptable: Detailed Below |
Please describe, in the space below, the enhancements needed or reasons for an "unacceptable" rating:
Reviewer's Name:
Reviewer's Title:
Reviewer's Company:
(Optional)
Date of Review:
Reviewer's Signature:
Additional Location Address (If Required)
Independent Review Form Page 9
Business Name/Business DBA:
Business Street Address:
City: State: Zip:
Business Name/Business DBA:
Business Street Address:
City: State:
Business Name/Business DBA:
Business Street Address:
City: State:
Business Name/Business DBA:
Business Street Address:
City: State:
Business Name/Business DBA:
Business Street Address:
City: State:
Business Name/Business DBA:
Business Street Address:
City: State:
Business Name/Business DBA:
Business Street Address:
City: State:
Zip:
Zip:
Zip:
Zip:
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Zip:
If additional locations blanks are needed, please copy this page and add accordingly.