Which of the following best describes the responsibilities of MSBs under the BSA?

The most accurate description of the responsibilities of Money Services Businesses (MSBs) under the Bank Secrecy Act (BSA) is that they must implement a comprehensive BSA/AML compliance program. MSBs are required to establish and maintain a program that includes policies, procedures, and internal controls designed to prevent money laundering and the financing of terrorism. This program must also include employee training and independent testing to ensure compliance with BSA regulations.

In addition, MSBs are obligated to report suspicious activities, file Currency Transaction Reports (CTRs), and maintain proper records, making it essential for them to have a robust compliance framework. This requirement is critical in helping to safeguard the financial system and ensure MSBs are actively monitoring for any potential illegal activity.

The other options do not accurately reflect the obligations placed on MSBs under the BSA. For instance, stating that they have no obligations misrepresents the extensive responsibilities MSBs have regarding regulatory compliance. The assertion that they can operate without reporting to FinCEN overlooks the necessity of reporting certain transactions, and claiming they are exempt from audits ignores the BSA's requirements for ongoing oversight and assessment of compliance programs.