A two-page field checklist covering structuring, customer behavior, transaction patterns, geographic risk, scam and elder-exploitation indicators, agent controls, and program gaps. Built from the same criteria used inside bank BSA departments.
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The same signals a bank BSA analyst is trained to look for when deciding whether your account stays open.
Deposits and transfers kept just under CTR and recordkeeping lines.
Reluctance, coaching, multiple names, single beneficiaries, and inconsistent explanations.
Activity that does not match the customer's known profile or stated business purpose.
High-risk destinations, layered routing, and unusual origin or destination patterns.
Romance scams, investment scams, pig-butchering indicators, and elder-exploitation signs.
Bypassed procedures, inconsistent filings, missing risk assessments, and review documentation gaps.
The fourth pillar of your AML program should identify gaps before your bank or examiner does. Fixed-fee, CAMS-certified reviews for MSBs start at $2,750.