Compliance with the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations is crucial for businesses operating in the financial sector. Accounting firms providing payroll services to clients need to ensure they are compliant with these regulations to avoid legal and reputational risks.

In this article, we will discuss the challenges and considerations that accounting firms face in maintaining BSA and AML compliance.

Learn more about partnering with Asure to provide payroll services to your clients.

The Changing Regulatory Landscape

Accounting firms may assume that BSA and AML regulations do not apply to them, but recent developments have challenged this belief. State banking regulations may require accounting firms to follow BSA guidelines, necessitating anti-money laundering measures and customer verification. It is essential for accounting firms to verify their state’s requirements to determine if they need to comply with BSA regulations.

Unwitting Non-Compliance

Many accounting firms providing payroll services may unknowingly be non-compliant with BSA and AML regulations. Lack of awareness and misconceptions about compliance obligations can lead to unintentional violations. The assumption that certain regulations do not apply to accounting firms can be detrimental. It is crucial for accounting firms to recognize the importance of compliance and take appropriate measures to rectify any non-compliance.

The Regulatory Interpretation and Enforcement

The regulatory landscape is evolving, with regulators clarifying the application of BSA and AML regulations to various industries. While the laws themselves may not have changed significantly, the enforcement and accountability have intensified. States, facing financial pressures, are actively seeking potential revenue sources, leading to increased scrutiny and enforcement of existing regulations.

The transition from regulatory interpretation to explicit legal definitions can have significant implications for compliance.

Challenges Faced by Accounting Firms

Accounting firms encounter several challenges in maintaining BSA and AML compliance. The costs associated with implementing necessary technology and resources can be burdensome, particularly for smaller firms. Integrating third-party resources for efficient screening and verification may require financial investment. The management of false positives, where legitimate customers are flagged as potential risks, can be time-consuming and resource-intensive.

Striking a balance between comprehensive screening and a seamless customer experience is crucial.

Keeping Up with Changing Trends

Financial crimes continually evolve, necessitating ongoing vigilance from accounting firms. Criminal entities adapt their methods to exploit vulnerabilities in the system, requiring firms to stay updated with the latest trends in money laundering and terrorist financing.

Real-time monitoring and proactive risk assessments are essential for identifying suspicious activities and taking prompt action. Accounting firms must invest in training and awareness programs to ensure their employees understand their compliance responsibilities.

Establishing Robust Compliance Programs

To ensure compliance with BSA and AML regulations, accounting firms should establish comprehensive compliance programs. These programs should include written policies, procedures, and controls tailored to the specific requirements of the firm.

Regular training and awareness programs foster a culture of compliance and enhance employees’ understanding of their responsibilities. Independent reviews and audits evaluate the effectiveness of the compliance program and identify areas for improvement.

Navigating the Regulatory Landscape

Federal and state regulators play a vital role in enforcing BSA and AML regulations. Accounting firms must stay informed about the specific requirements of both federal and state regulators to ensure compliance.

Maintaining open lines of communication with regulators and seeking guidance when needed can help accounting firms navigate the complex landscape of compliance. Non-compliance can lead to severe penalties and legal consequences, making it crucial for firms to prioritize compliance efforts.


Complying with BSA and AML regulations is paramount for accounting firms providing payroll services. Understanding the changing regulatory landscape, overcoming compliance challenges, and staying updated with evolving trends are essential for ensuring compliance.

Accounting firms that provide payroll services should consider implementing compliance training and awareness programs.

Learn more about partnering with Asure to provide payroll services to your clients.

Watch our video, NACHA, Bank Secrecy Act, Money Transmitter Law: What Businesses Must Know

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