Definition
Bank Secrecy Act / anti-money laundering and counter-terrorist financing compliance programs — transaction monitoring, SAR filing, independent review, and governance — required of banks and money services businesses.
Key Points
- Wise US July 2025 multistate consent order ($4.2M) cited in OCC trust charter denial
- OCC expects enterprise-wide AML/CFT commensurate with payment volume/risk before trust/bank charters
- MSB compliance record scrutinized when applicants seek bank-level requirements