Who is primarily responsible for adhering to the BSA's compliance requirements?

The primary responsibility for adhering to the Bank Secrecy Act's compliance requirements falls on registered Money Services Businesses (MSBs). MSBs, which include businesses such as currency exchangers, check cashers, and money transfer services, are subject to the BSA's requirements because they engage in financial activities that could potentially lead to money laundering or other illicit financial activities.

These businesses must implement appropriate internal controls, conduct customer due diligence (CDD), file suspicious activity reports (SARs), and maintain records to comply with the BSA. They are also required to develop a comprehensive compliance program and adequately train employees on BSA requirements.

While customers of banks, bank owners, and federal regulators play crucial roles in the overall compliance ecosystem, their responsibilities differ. Customers must provide accurate information but do not manage compliance directly. Bank owners have a vested interest in compliance; however, they rely on compliance officers to execute the BSA's requirements. Federal regulators oversee and enforce compliance, providing guidance and conducting examinations, but the direct compliance responsibility primarily lies with the entities engaged in offering financial services, specifically the registered MSBs in this context.