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CT AML BSA Compliance

The course teaches BSA/AML foundations, customer due diligence, KYC, red‑flag recognition, sanctions and PEP compliance, and SAR/CTR reporting, enabling financial‑institution employees to detect and prevent money‑laundering and terrorist financing.

Who Should Take This

Front‑line staff, compliance analysts, and junior managers at banks, credit unions, and other covered entities benefit from this training. They typically have limited AML experience and need practical guidance to meet regulatory obligations, recognize suspicious activity, and conduct proper due‑diligence. Their goal is to strengthen institutional risk controls and avoid costly penalties.

What's Included in AccelaStudy® AI

Adaptive Knowledge Graph
Practice Questions
Lesson Modules
Console Simulator Labs
Exam Tips & Strategy
20 Activity Formats

Course Outline

65 learning goals
1 BSA/AML Foundations
2 topics

Regulatory framework overview

  • Identify the purpose and key provisions of the Bank Secrecy Act of 1970 including the requirement for financial institutions to assist government agencies in detecting and preventing money laundering.
  • Describe how the USA PATRIOT Act expanded BSA requirements including enhanced CDD, expanded SAR filing obligations, information sharing provisions, and anti-terrorist financing measures.
  • Identify FinCEN's role as the primary BSA administrator and its authority to issue regulations, collect reports, share information with law enforcement, and impose civil monetary penalties.
  • Describe the five pillars of an effective BSA/AML compliance program: internal controls, independent testing, designated BSA officer, training, and customer due diligence.

Money laundering fundamentals

  • Identify the three stages of money laundering: placement (introducing illicit funds), layering (concealing the trail), and integration (merging laundered funds into the legitimate economy).
  • Describe common money laundering methods including structuring (smurfing), shell companies, trade-based laundering, real estate purchases, casino laundering, and funnel accounts.
  • Explain the connection between money laundering and predicate offenses including drug trafficking, fraud, corruption, human trafficking, tax evasion, and terrorist financing.
  • Analyze transaction patterns to identify characteristics consistent with placement, layering, or integration stages of money laundering.
2 Customer Due Diligence and KYC
3 topics

Customer identification and verification

  • Identify Customer Identification Program (CIP) requirements including collecting name, date of birth, address, and identification number for individuals and equivalent information for entities.
  • Describe acceptable forms of identification for CIP verification including government-issued photo ID, passport, and the documentary and non-documentary verification methods.
  • Explain the requirement to verify customer identity within a reasonable time after account opening and the obligation to maintain CIP records for five years after account closure.

Beneficial ownership and risk-based CDD

  • Identify the beneficial ownership rule requiring identification of individuals who own 25% or more of a legal entity and a single individual with significant management control.
  • Describe the CDD requirement to understand the nature and purpose of customer relationships, develop customer risk profiles, and conduct ongoing monitoring for suspicious activity.
  • Explain Enhanced Due Diligence (EDD) requirements for high-risk customers including foreign correspondent accounts, private banking clients, PEPs, and customers in high-risk jurisdictions.
  • Analyze a customer profile to assess the risk level and determine whether standard CDD or Enhanced Due Diligence is required based on customer type, geography, products, and transaction patterns.

Ongoing monitoring and periodic review

  • Describe the requirement for ongoing monitoring of customer relationships including transaction monitoring, periodic KYC updates, and reassessment of customer risk ratings.
  • Identify triggers for updating customer due diligence including significant changes in transaction patterns, adverse media, changes in ownership structure, and regulatory alerts.
  • Explain the process for conducting periodic reviews of high-risk customers including refreshing documentation, reassessing risk ratings, and determining whether to maintain the relationship.
3 Suspicious Activity and Transaction Reporting
3 topics

Suspicious Activity Reports (SARs)

  • Identify the SAR filing obligation when a transaction is conducted or attempted by, at, or through the institution and the institution knows, suspects, or has reason to suspect suspicious activity.
  • Describe the SAR filing thresholds including $5,000 for insider abuse, $5,000 for identified suspects, and $25,000 when no suspect is identified, and explain when these apply.
  • Explain the 30-day SAR filing deadline from initial detection, the 60-day extension when no suspect is identified, and the requirement for continuing SARs on ongoing suspicious activity.
  • Describe the absolute confidentiality requirement for SARs prohibiting disclosure to the subject of the SAR and any unauthorized person, and the safe harbor protection for good-faith filers.
  • Analyze a suspicious transaction scenario to determine whether SAR filing is required, identify the relevant filing threshold, and describe the information needed for the SAR narrative.

Currency Transaction Reports (CTRs)

  • Identify the CTR filing requirement for cash transactions exceeding $10,000 in a single business day including deposits, withdrawals, currency exchanges, and other cash transactions.
  • Describe the aggregation rule requiring multiple cash transactions by or on behalf of the same person to be combined when they total more than $10,000 in a single business day.
  • Explain the CTR exemption process for eligible customers including categories of exempt persons, the biennial renewal requirement, and monitoring obligations for exempt customers.
  • Analyze cash transaction scenarios to determine whether CTR filing is required, applying aggregation rules and evaluating potential exemptions.

Other BSA reporting requirements

  • Identify the FBAR (FinCEN Report 114) requirement for US persons to report foreign financial accounts exceeding $10,000 in aggregate value at any time during the calendar year.
  • Describe the Currency and Monetary Instrument Report (CMIR) filing requirement for physically transporting currency or monetary instruments exceeding $10,000 into or out of the United States.
  • Explain the beneficial ownership reporting requirements under the Corporate Transparency Act requiring entities to report beneficial ownership information to FinCEN.
4 Red Flags and Suspicious Activity Recognition
3 topics

Transaction-based red flags

  • Recognize structuring indicators including multiple cash deposits or withdrawals just below $10,000, using multiple branches or tellers, and breaking up transactions across consecutive days.
  • Identify wire transfer red flags including transactions to or from high-risk jurisdictions, lack of apparent business purpose, round-dollar amounts, and rapid fund movements through multiple accounts.
  • Recognize unusual account activity patterns including sudden increases in transaction volume, activity inconsistent with customer profile, dormant accounts with sudden large transactions, and frequent currency exchanges.
  • Analyze a customer's transaction history to identify patterns consistent with money laundering red flags and determine whether the activity warrants escalation for SAR consideration.

Customer behavior red flags

  • Recognize customer behavior red flags including reluctance to provide identification, excessive concern about reporting thresholds, use of aliases, and attempts to discourage normal documentation.
  • Identify red flags related to business accounts including cash-intensive businesses with no apparent customers, businesses with revenues inconsistent with industry norms, and shell company indicators.
  • Describe red flags specific to trade-based money laundering including over- or under-invoicing, misrepresentation of goods, multiple invoicing for the same shipment, and phantom shipments.

Terrorist financing indicators

  • Recognize how terrorist financing differs from money laundering in that funds may originate from both legitimate and illegitimate sources and often involve small amounts below reporting thresholds.
  • Identify red flags for terrorist financing including transactions linked to conflict zones, donations to unverified charities, and rapid movement of funds through accounts with no apparent economic purpose.
  • Describe the obligation to screen transactions and customers against terrorist watchlists and the legal requirement to block and report transactions involving designated terrorist organizations.
  • Analyze a customer's transaction pattern to evaluate whether the activity is consistent with terrorist financing indicators and determine the appropriate escalation action.
5 Sanctions Compliance and PEPs
3 topics

OFAC sanctions screening

  • Identify the role of OFAC (Office of Foreign Assets Control) in administering US economic sanctions programs and the obligation to screen customers, transactions, and counterparties against OFAC lists.
  • Describe the Specially Designated Nationals (SDN) list and other OFAC sanctions lists and explain the requirement to block transactions and freeze assets of designated persons and entities.
  • Explain the strict liability nature of OFAC sanctions violations meaning penalties apply regardless of whether the institution knew it was dealing with a sanctioned party.
  • Describe the proper response to an OFAC screening match including blocking or rejecting the transaction, filing a report with OFAC, and not disclosing the match to the customer.

Politically Exposed Persons

  • Identify the definition of Politically Exposed Persons (PEPs) including foreign senior political figures, their immediate family members, and close associates.
  • Describe Enhanced Due Diligence requirements for PEPs including determining the source of funds and wealth, senior management approval for relationships, and ongoing enhanced monitoring.
  • Analyze a customer relationship to determine whether the individual qualifies as a PEP and evaluate the appropriate level of due diligence and ongoing monitoring required.

High-risk jurisdictions and correspondent banking

  • Identify high-risk jurisdictions as designated by FATF, FinCEN, and OFAC and describe the enhanced scrutiny required for transactions involving these countries.
  • Describe the enhanced due diligence requirements for correspondent banking relationships including assessing the respondent bank's AML controls and prohibitions on shell bank relationships.
  • Explain the prohibition on maintaining correspondent accounts for foreign shell banks and the obligation to take reasonable steps to prevent indirect access through nested correspondent accounts.
  • Analyze a cross-border transaction to evaluate jurisdiction risk, determine whether enhanced screening is required, and identify potential sanctions or high-risk country implications.
6 Employee Obligations, Training, and Penalties
4 topics

Employee reporting obligations

  • Identify the employee's obligation to report suspicious activity to the BSA officer or designated compliance personnel and never attempt to independently investigate or alert the customer.
  • Describe the prohibition on tipping off customers about SAR filings, investigations, or suspicious activity reports and the legal consequences of unauthorized disclosure.
  • Explain the importance of documenting observations of suspicious activity including recording specific behaviors, transaction details, customer statements, and timing for referral to compliance.
  • Synthesize an internal suspicious activity referral documenting observed red flags, relevant customer background, transaction details, and the basis for suspicion for compliance review.

Information sharing provisions

  • Describe Section 314(a) mandatory information sharing requiring financial institutions to search records in response to FinCEN requests related to money laundering or terrorist financing investigations.
  • Explain Section 314(b) voluntary information sharing allowing financial institutions to share information with each other to identify and report money laundering and terrorist financing under safe harbor protection.

Penalties and consequences

  • Identify civil monetary penalties for BSA/AML violations including fines up to $1 million per violation per day for willful violations and the personal liability of compliance officers and employees.
  • Describe criminal penalties for money laundering including fines up to $500,000 or twice the amount laundered and imprisonment up to 20 years under 18 USC 1956 and 1957.
  • Explain regulatory consequences beyond fines including cease and desist orders, consent orders, removal of officers and directors, and loss of charter or banking license.
  • Analyze an enforcement case to identify which BSA/AML requirements were violated, evaluate the institution's compliance program deficiencies, and describe what preventive measures could have avoided the penalty.

Training and compliance culture

  • Identify BSA/AML training requirements including role-specific training, annual refresher training, training on new regulations and typologies, and documentation of training completion.
  • Describe the importance of a strong compliance culture including tone from the top, clear escalation procedures, non-retaliation policies, and integration of compliance into business processes.
  • Synthesize a compliance awareness plan for a department incorporating red flag recognition training, escalation procedures, documentation standards, and metrics for measuring compliance effectiveness.

Scope

Included Topics

  • Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) compliance training for employees in financial institutions, money services businesses, and other covered entities.
  • BSA/AML regulatory framework including the Bank Secrecy Act of 1970, USA PATRIOT Act provisions, Anti-Money Laundering Act of 2020, and FinCEN regulatory authority.
  • Customer Due Diligence (CDD) and Know Your Customer (KYC) requirements including customer identification programs (CIP), beneficial ownership identification, risk-based due diligence, and enhanced due diligence (EDD) for high-risk customers.
  • Suspicious Activity Report (SAR) filing requirements including recognition of suspicious activities, SAR content requirements, filing timelines, and confidentiality obligations.
  • Currency Transaction Report (CTR) filing requirements for cash transactions exceeding $10,000, aggregation rules, and exemption procedures.
  • Money laundering stages (placement, layering, integration), common money laundering techniques, and red flags indicating potential illicit financial activity.
  • Politically Exposed Persons (PEPs) identification, OFAC sanctions screening, denied party lists, and sanctions compliance obligations.
  • FinCEN requirements including beneficial ownership reporting, Geographic Targeting Orders, and Section 314(a) and 314(b) information sharing provisions.
  • Employee obligations, training requirements, compliance program elements, and penalties for BSA/AML violations at both institutional and individual levels.

Not Covered

  • Detailed bank examination procedures, FFIEC BSA/AML examination manual methodologies, or regulatory examination preparation.
  • Anti-money laundering compliance program design for specific financial products (derivatives, cryptocurrency exchanges, correspondent banking) beyond awareness level.
  • International AML frameworks (EU Anti-Money Laundering Directives, FATF Recommendations) beyond their relationship to US BSA/AML requirements.
  • Technical implementation of transaction monitoring systems, sanctions screening software, or case management platforms.
  • Criminal investigation techniques, law enforcement procedures, or prosecution strategies for money laundering cases.

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