Streamline Corporate Filing Management for Your MSB

A corporate file is the foundation of your MSB’s Customer Due Diligence (CDD) process. It documents everything regulators expect to see when assessing how well you know your business customers. Each file should include the company’s formation documents, ownership information, tax ID number, proof of business location, identification for all authorized signers, and a clear description of the business purpose.

Maintaining these files is not just a formality—it demonstrates that your MSB has verified who it is doing business with, understands the nature of each customer’s operations, and can justify its risk rating. During examinations, regulators frequently use corporate files to assess whether an MSB’s risk controls are strong or merely “check-the-box” procedures.

Customer Due Diligence (CDD) is the standard process for gathering and verifying information about a business customer. It includes identifying the company, understanding its ownership structure, and determining its expected transaction activity.

Enhanced Due Diligence (EDD) applies when a customer presents elevated risk factors—such as cash- intensive operations, out-of-state ownership, or activity inconsistent with its business type. EDD digs deeper, requiring verification of the source of funds, analysis of financial statements, site visits, or review of historical transaction trends. The goal is to ensure the MSB has a complete understanding of the customer’s legitimacy and potential exposure to financial crime.

Corporate files are living documents. Ownership, addresses, insurance coverage, or business activity can change without notice, which can quickly make a once-compliant file outdated. Regulators expect MSBs to review and refresh these files at least annually—or immediately when a material change occurs.

Outdated files are one of the most common and easily avoidable findings. An incomplete file signals to regulators that your monitoring program may also be weak, since current customer information directly affects transaction review and risk scoring.

Florida Chapter 560 and Rule 69V-560 establish specific documentation standards for corporate customers. Each file must contain:

• Articles of incorporation, partnership agreement, or other proof of formation.
• County business tax receipt.
• Identification for all owners and authorized signers.
• Corporate customer profile sheet.
• Workers’ compensation database search results.
• Copy of workers’ compensation declaration page (if insurance is held).
• Verification of active corporate status with the Florida Division of Corporations.
• Proof of Federal Employer Identification Number.
• Annual attestation by the compliance officer that the file is complete.

These documents collectively demonstrate that the customer is a legitimate operating business and not a shell entity or front for unlicensed activity.

Florida requires corporate files to be reviewed and updated at least every 12 months and whenever there is a material change regarding the business. Examiners from the Office of Financial Regulation (OFR) will select a random sample of corporate customers during audits to test whether files are current and complete.

A good practice is to create an internal review schedule that aligns file updates with your annual independent review cycle. This shows regulators that you are maintaining proactive oversight rather than reacting to deficiencies after the fact.

Yes. Florida Rule 69V-560.704 requires MSBs to verify and document Workers’ Compensation coverage. If the customer does not maintain coverage, then a written statement signed by the customer as to the reason they are not required to have insurance must be in the file.

Additionally, the search results for the query conducted in the Workers’ Compensation Coverage database must be conducted and printed regardless as to whether or not coverage is maintained.

Failure to maintain complete and accurate corporate files can lead to serious consequences, including fines, orders to cease operations or license suspension/revocation. Regulators view poor documentation as evidence of ineffective CDD and weak AML controls and in Florida it is a 3rd degree felony.

In addition to penalties, incomplete files damage your credibility with banking partners. Banks expect MSBs to maintain robust customer files since those same documents are relied upon during account onboarding and ongoing due diligence reviews.

Yes. Florida permits MSBs to keep corporate files in electronic format as long as they are complete, organized, and immediately accessible during examinations. Digital recordkeeping can significantly improve efficiency and reduce the chance of missing documentation.

The key is maintaining secure storage, access controls, and clear indexing so every document can be retrieved quickly upon request.

ComplyCheck’s Corporate File Management System centralizes all customer documentation in a secure, searchable database. It tracks all required documentation with corresponding expiration dates, monitors active business status with the Division of Corporations, and flags missing or outdated items before they become audit findings. Health Reports, which are automated weekly details on missing or out-of-date documents that need to be addressed to maintain compliance. These reports are also downloadable on- demand.

Each file is structured to satisfy both federal CDD/EDD standards and Florida Rule 69V-560 documentation requirements, ensuring that your compliance files are always organized, exam-ready, and regulator-proof.

Prior to an OFR or IRS examination, ComplyCheck conducts a detailed review of every corporate file, verifying that all documentation is accurate and current. We prepare a summary report identifying any gaps, provide corrective guidance, and help assemble examiner-ready binders or digital folders.

Our clients frequently complete audits with no findings in this category because examiners can easily see that documentation is consistent, verifiable, and professionally maintained—proof that your MSB takes compliance seriously.