Performing an annual Independent Review

Every Money Service Business needs to perform an Independent Review, and most crypto banks ask for this document annually.

What is an Independent Review?

  • The Independent Review (sometimes called an Audit) is a requirement of the Bank Secrecy Act – the purpose is to test the Anti-Money Laundering program.
  • The Review should provide a fair and unbiased appraisal of each of the required elements of the company’s anti-money laundering program, including its Bank Secrecy Act-related policies, procedures, internal controls, record-keeping, reporting functions, and training.
  • The review should include testing of internal controls and transactional systems and procedures to identify problems or weaknesses, and if necessary, provide recommendations to management with appropriate corrective actions.
  • The review needs to be documented, and made available to banks or IRS Title 31 examiners if necessary. government examiners and law enforcement authorities if necessary. Learn more here.

Required Documents for the Independent Review

Clients of Hodder Law must provide the following documents to get started on the Review:

  1. Copy of MSB registration and verification
  2. List of locations and their address
  3. Anti-Money Laundering (AML) program
  4. Risk Assessment
  5. OFAC Policy
  6. State No Action Letters / Opinion Letters
  7. Transaction reports for the review period
  8. Record of crypto purchases during the review period
  9. Record of Suspicious Activity Reports filed during the review period
  10. Record of Currency Transaction Reports filed during the review period
  11. Compliance Officer’s resume
  12. Any correspondence with the IRS or FInCEN during the past two years
  13. Record of any compliance training
  14. Record of document storage procedures
  15. Most updated Terms of Service and Privacy Policy
  16. Description of software
  17. Flow of Funds diagram
  18. Board meeting records
  19. Website address
  20. Certificate of Good Standing

Please let us know if we can help with your Independent Review or anything else related to crypto law!


Hodder Law Firm, P.A.

E: Katrina@Hodder.Law

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