BSA Compliance Program Checklist. Download Free.
A comprehensive, examiner-aligned checklist covering all 8 pillars of a BSA/AML compliance program. Built for compliance officers and small regulated businesses who need clarity fast.
AML Requirements Are Unclear. Small Businesses Get Left Behind.
FinCEN expects every covered business to maintain a complete BSA/AML compliance program. But the regulations are written for large financial institutions, not small mortgage brokerages, MSBs, or title companies. Most compliance officers spend weeks trying to figure out what is actually required.
The result: incomplete programs, missing documentation, and costly examination findings. A single Matters Requiring Attention (MRA) can take months to remediate and cost thousands in consultant fees.
No clear starting point
Regulations reference broad requirements without a step-by-step framework for small businesses.
Generic templates do not fit
Bank-focused AML templates ignore industry-specific risks like wire fraud, loan fraud, or cash structuring.
Examiners find the same gaps
Missing risk assessments, overdue independent reviews, and undocumented training are the top 3 findings every year.
Time and budget pressure
Small businesses cannot afford a full-time compliance officer or expensive outside counsel for basic program setup.
What a Finding Costs You
Up to $286,184
Per willful BSA violation (31 CFR 1010.821)
90 Days
Typical MRA remediation deadline
$15K+
Average consultant fees to fix gaps
License Risk
State or federal license suspension
Why This Checklist Helps
Maps every FinCEN requirement to a yes/no checklist item
Identifies gaps before an examiner does
Provides industry-specific notes for MSBs, mortgage, title, and more
Serves as evidence of good-faith compliance efforts
Free, no payment or commitment required
8 Pillars of a BSA/AML Compliance Program
Every item in the checklist is aligned with FinCEN requirements and common examination findings. Download the full checklist to assess your program.
Written AML Policies & Procedures
7 checklist items
- Formal policy manual covering all products, services, and customer types
- Customer Identification Program (CIP) with document requirements
- Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures
- Suspicious Activity Report (SAR) filing process and escalation chain
- Currency Transaction Report (CTR) filing for applicable industries
- Record retention policy (minimum 5 years)
- Ongoing monitoring and periodic review schedule
BSA/AML Risk Assessment
6 checklist items
- Identified inherent risks by product, service, customer, and geography
- Documented risk ratings (low, moderate, high) with justification
- Mapped internal controls to each identified risk
- Residual risk analysis after controls are applied
- Annual review and update cycle documented
- Board or senior management approval on file
Designated BSA/AML Compliance Officer
6 checklist items
- Named individual with explicit job description and authority
- Sufficient time allocation for compliance duties
- Direct reporting line to senior management or board
- Documented qualifications and experience
- No conflicts of interest with audited operations
- Backup officer designated for absences
Annual Employee Training Program
6 checklist items
- Role-specific curriculum for all relevant employees
- New hire training within 30 days of start date
- Annual refresher training for existing staff
- Documented completion records and attendance logs
- Certificates of completion retained for 5 years
- Board and senior management receive tailored training
Independent Testing / Annual Review
6 checklist items
- Conducted by a qualified independent party at a risk-based frequency
- Scope covers all AML program components
- Testing methodology documented and risk-based
- Findings reported to board or senior management
- Corrective action plans with timelines for deficiencies
- BSA officer does not review their own program
Transaction Monitoring & Reporting
6 checklist items
- Automated or manual monitoring for suspicious patterns
- SAR filing within 30 calendar days of detection (up to 60 if no suspect is identified)
- CTR filing for currency transactions over $10,000
- SAR/CTR quality assurance and narrative standards
- Investigation documentation and decision rationale
- No disclosure of SAR filing to subject (tipping off)
OFAC Compliance & Sanctions Screening
6 checklist items
- Interdiction software or manual screening process
- Real-time screening for new customers and transactions
- Blocked property reporting and compliance procedures
- Recordkeeping for OFAC matches and resolutions
- Annual OFAC policy review and update
- Escalation process for potential sanctions matches
Recordkeeping & Documentation
6 checklist items
- All CIP records retained for 5 years after account close
- Transaction records retained for 5 years
- SAR supporting documentation retained for 5 years
- CTR copies and BSA registration documents current
- Electronic and physical records secured and accessible
- Document retention schedule tested and verified
Get the BSA Compliance Checklist
Enter your details below and get instant access to the complete checklist. We will also send you a copy via email for your records.
Checklist Complete? Now Let Soflo Implement It for You.
Downloading the checklist is step one. But if you have items marked Missing or Partial, you need a partner who can close the gaps fast. Soflo Consulting builds and maintains BSA/AML programs for small regulated businesses.
Custom AML Policy Manual
Drafted for your specific industry, products, and customer base. Not a generic template.
BSA Risk Assessment
Identifies your actual risks and documents controls. Required by FinCEN in every examination.
Employee Training Program
Industry-specific online training with auto-generated certificates and manager dashboard.
Independent Review Preparation
We help you prepare documentation for a qualified independent review. Independent testing must be performed by a party independent of your program; Soflo does not perform it.
Full Suite Plan
Tools and documentation for a strong AML program
- Custom AML policy manual
- BSA risk assessment
- Annual employee training (all seats)
- Auto-generated certificates
- Annual program document review (not independent testing)
- Manager compliance dashboard
- SAR/CTR filing procedures
- OFAC compliance procedures
Starting at
$1,800/year
BSA Compliance Checklist: Common Questions
Is the BSA compliance checklist really free?
Yes. The checklist is completely free to download. We only ask for your email so we can send you the download link and follow up with helpful compliance tips. We do not sell your information or share it with third parties.
What industries does the checklist cover?
The checklist is designed to apply to all businesses subject to the Bank Secrecy Act, including money services businesses (MSBs), mortgage lenders and originators, dealers in precious metals and high-value goods, insurance companies, casinos, and fintech companies. Each section includes notes on industry-specific variations.
Can I use this checklist for a regulator examination?
The checklist is intended as a self-assessment and preparation tool. While it covers the same components regulators examine, it does not replace a formal independent review. We recommend using the checklist to identify gaps before engaging a compliance consultant for your independent annual review.
What if I need help implementing the checklist items?
Soflo Consulting provides full BSA/AML program implementation services. We can draft your AML policy, review your risk assessment and build your training program. We don't perform independent testing, but we can help you prepare for it. Contact us to talk to a compliance professional about your specific needs.
Download the Checklist. Then Close the Gaps.
The BSA compliance checklist is free and takes 10 minutes to complete. If you find gaps, Soflo can help: training access is immediate, and professional Review and Creation deliverables follow the timelines in our Terms.