BSA AML Compliance Review Checklist [FREE PDF]

The Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations require financial institutions to maintain robust compliance programs under 31 CFR Chapter X and FinCEN guidance. Institutions must implement adequate internal controls, conduct independent testing, and designate a qualified compliance officer as outlined in the FFIEC BSA/AML Examination Manual. Regular compliance reviews help identify program deficiencies before regulatory examinations and protect institutions from civil mon

  • Industry: Banking
  • Frequency: Quarterly
  • Estimated Time: 60-90 minutes
  • Role: Compliance Officer
  • Total Items: 37
  • Compliance: 31 CFR Chapter X (BSA Regulations), FinCEN BSA/AML Examination Manual 2022, 31 U.S.C. 5318 - Compliance, Due Diligence, Recordkeeping, 31 CFR 1020.320 - SAR Filing Requirements, 31 CFR 1010.311 - CTR Filing Requirements

BSA/AML Program Governance

Assess the foundational governance structure of the BSA/AML compliance program including board oversight and officer designation.

  • Has the board of directors formally approved a written BSA/AML compliance program within the past 12 months?
  • Is a designated BSA Compliance Officer formally appointed in writing with documented qualifications?
  • Has the BSA Officer received adequate training within the past 12 months relevant to current regulatory requirements?
  • Are BSA/AML program updates communicated to senior management and the board with documented evidence?
  • Does the institution have an adequate BSA/AML budget with documented resource allocation?

Customer Identification Program (CIP)

Evaluate the institution's CIP procedures for collecting, verifying, and retaining customer identification information.

  • Does the CIP collect all required identifying information (name, DOB, address, ID number) for every new account?
  • Are identity verification procedures documented and consistently applied for both documentary and non-documentary methods?
  • Is customer identification information retained for a minimum of 5 years after account closure?
  • Are customers screened against OFAC SDN list at account opening and on an ongoing basis?
  • Are CIP exceptions tracked, escalated, and resolved within documented timeframes?
  • Does the institution maintain a customer notice of CIP requirements as required?

Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

Verify that CDD and EDD procedures meet FinCEN requirements for beneficial ownership and risk-based monitoring.

  • Are beneficial ownership requirements collected for all legal entity customers at account opening (25% threshold)?
  • Is a risk-based customer risk rating system in place and applied consistently across all customer segments?
  • Are Enhanced Due Diligence (EDD) procedures applied to all high-risk customers including PEPs and foreign correspondent banks?
  • Are customer risk ratings reviewed and updated at least annually or upon triggering events?
  • Is there a documented process for identifying and exiting high-risk relationships that cannot be adequately managed?

Transaction Monitoring & Suspicious Activity Detection

Evaluate the effectiveness of transaction monitoring systems and alert management processes.

  • Is an automated transaction monitoring system in place with documented tuning and validation records?
  • Are transaction monitoring alert backlogs maintained at manageable levels with documented resolution timeframes?
  • Are alert dispositions documented with sufficient narrative to support the investigation decision?
  • Are staff conducting transaction monitoring reviews adequately trained and credentialed?
  • Does the monitoring program include coverage of all transaction channels including wire transfers, ACH, and cash?
  • Is the current transaction monitoring alert volume and closure rate documented for this review period?

SAR & CTR Filing Compliance

Assess the timeliness, accuracy, and completeness of Suspicious Activity Report and Currency Transaction Report filings.

  • Are all SARs filed within the required 30-day deadline (60 days if no suspect identified) per FinCEN requirements?
  • Are SAR narratives complete, accurate, and include the who, what, when, where, why, and how of the suspicious activity?
  • Are Currency Transaction Reports (CTRs) filed for all cash transactions exceeding $10,000 within the required timeframe?
  • Are CTR exemptions properly documented, reviewed annually, and limited to eligible businesses?
  • Is there a SAR confidentiality policy preventing disclosure to subjects with documented employee acknowledgment?

Training Program & Independent Testing

Evaluate the completeness of BSA/AML training records and the scope of independent audit testing.

  • Have all applicable employees completed BSA/AML training within the past 12 months with documented completion records?
  • Has an independent BSA/AML audit been completed within the past 12 months by qualified internal or external auditors?
  • Are all prior audit findings tracked in a management action plan with target remediation dates?
  • Does training content cover current FinCEN advisories, geographic targeting orders, and emerging typologies?
  • Is the independent testing scope sufficient to cover all BSA/AML program pillars and high-risk areas?

Recordkeeping & Information Sharing

Confirm that recordkeeping and Section 314 information sharing obligations are being met.

  • Are wire transfer records maintained for all transfers of $3,000 or more with all required data elements?
  • Does the institution respond to Section 314(a) information requests from FinCEN within the required 14-day timeframe?
  • Is the institution registered for the Section 314(b) voluntary information sharing program with current registration?
  • Are all BSA records retained for a minimum of 5 years and readily available for regulatory examination?
  • Are there documented procedures for responding to law enforcement subpoenas and legal process related to BSA records?

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Why Use This BSA AML Compliance Review Checklist [FREE PDF]?

This bsa aml compliance review checklist [free pdf] helps banking teams maintain compliance and operational excellence. Designed for compliance officer professionals, this checklist covers 37 critical inspection points across 7 sections. Recommended frequency: quarterly.

Ensures compliance with 31 CFR Chapter X (BSA Regulations), FinCEN BSA/AML Examination Manual 2022, 31 U.S.C. 5318 - Compliance, Due Diligence, Recordkeeping, 31 CFR 1020.320 - SAR Filing Requirements, 31 CFR 1010.311 - CTR Filing Requirements. Regulatory-aligned for audit readiness and inspection documentation.

Frequently Asked Questions

What is a BSA AML Compliance Review Checklist [FREE PDF]?

A BSA AML Compliance Review Checklist [FREE PDF] is a standardized inspection form used by compliance officer to ensure consistent banking operations. It contains 42 inspection points organized into 7 sections. FREE BSA/AML compliance review checklist PDF. Covers CIP, SAR filing, CTR reporting & transaction monitoring per FinCEN regulations.

How often should I use this banking checklist?

This checklist is designed to be completed quarterly. Regular use ensures compliance with 31 CFR Chapter X (BSA Regulations) and FinCEN BSA/AML Examination Manual 2022 and helps identify issues before they become problems.

Can I download this BSA AML Compliance Review Checklist [FREE PDF] as a PDF?

Yes, you can download this checklist as a FREE PDF for printing or offline use. The checklist includes 42 fields across 7 sections and typically takes 60-90 minutes to complete.

What compliance standards does this checklist cover?

This checklist helps ensure compliance with 31 CFR Chapter X (BSA Regulations), FinCEN BSA/AML Examination Manual 2022, 31 U.S.C. 5318 - Compliance, Due Diligence, Recordkeeping, 31 CFR 1020.320 - SAR Filing Requirements, 31 CFR 1010.311 - CTR Filing Requirements. Following these standards protects your organization and ensures best practices.

How do I complete this banking inspection checklist?

Begin by completing the header fields for Review Date & Time, Compliance Officer / Reviewer Name, Branch / Department Location, Review Period (Quarter/Year), and Number of Outstanding Prior Findings. Work through each of the 7 sections, marking items Yes or No as applicable. The entire process takes approximately 60 to 90 minutes.

What are the key sections in this banking checklist?

This banking checklist is organized into 7 key sections: BSA/AML Program Governance, Customer Identification Program (CIP), Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD), Transaction Monitoring & Suspicious Activity Detection, SAR & CTR Filing Compliance, Training Program & Independent Testing, Recordkeeping & Information Sharing. Each section contains specific inspection points that compliance officer must verify. The structured layout ensures nothing is missed during banking inspections and makes the process efficient, typically taking 60-90 minutes to complete.

Who should use this BSA AML Compliance Review Checklist [FREE PDF]?

This checklist is primarily designed for compliance officer working in banking operations. However, it is also valuable for quality assurance teams, safety officers, compliance managers, and supervisors who need to verify that banking standards are being met. Organizations of all sizes can benefit from using this BSA AML Compliance Review Checklist [FREE PDF] to maintain consistency and accountability.

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