Is Your BSA Workflow Working—or Is Your Team Working Around It?

Review the work before adding another workaround. A practical guide for community banks and credit unions evaluating their BSA processes and technology.

Before adding another tracking sheet to your BSA process, ask a more useful question: What problem would it solve—and could your existing tools and procedures support that work more effectively?

Consider a routine handoff. One employee identifies activity for review. Another gathers customer context. A BSA reviewer documents a decision. When an authorized colleague needs to understand where the work stands, can they find the answer through the approved process, or must they reconstruct it from email, notes and a separate tracker?

The goal is not to put every BSA responsibility into one system or eliminate every manual step. It is to understand where work belongs, which handoffs function well and where additional effort may be hiding a process, training or technology gap.

Start with one workflow, not the entire program

Choose a defined activity: reviewing a monitoring alert, receiving a referral to BSA, or completing a customer risk or enhanced-due-diligence review. Ask the authorized employees involved to show how that work moves through the institution’s approved systems and procedures.

Observe where customer and activity context is found, how responsibility changes hands, where investigation documentation belongs and how staff identify unfinished work. Include backup coverage: can another authorized employee locate the information needed to continue?

Keep customer information, case identifiers, SAR-related information and reporting decisions in approved, access-controlled systems. Record only process observations in the review guide. Use a fictional example for any discussion with an external provider.

Separate necessary work from avoidable workarounds

A second tool or a manual step is not automatically a problem. It may support an appropriate approval, access restriction or specialized responsibility. The question is whether its purpose is clear and whether staff can use it consistently.

For each extra step, ask what it accomplishes. Does it add analysis or an approval, or does it repeat information already maintained elsewhere? Does it help someone complete the work, or mainly help colleagues find out where the work stands?

Also distinguish a capability gap from a usage gap. Before requesting new technology, check whether an existing function, a configuration change, clearer procedures, training or additional capacity could address the need. Keep uncertainty visible until it has been checked.

An example: the tracker beside the case record

Imagine a fictional institution where reviewers document investigations in their approved case system but retype assignment and status information into a spreadsheet for a weekly meeting. When a reviewer is absent, colleagues rely on email to determine who should act next.

The useful observation is not simply that the institution uses a spreadsheet. It is that staff repeat status information and may need to reconcile two records to understand current work.

A useful next step is to verify whether the current system and procedures can give authorized staff the needed view. If not, define that as a requirement for a product discussion. Do not remove the existing process until an approved alternative has been evaluated.

Turn observations into requirements a provider can demonstrate

Replace a broad request such as “We need better case management” with a specific question grounded in the workflow you observed.

When ownership is hard to locate: Ask the provider to show how an investigation is assigned, reviewed and handed to another authorized person in the current product.

When information is entered twice: Identify the repeated entry and ask which steps the product supports directly, which require configuration and which remain the institution’s responsibility.

When decisions are hard to follow: Ask where investigation notes, supporting information, review steps and closure are documented, and how an authorized colleague accesses them.

These are evaluation questions, not assurances that a particular product includes every requested capability. Ask to see the current workflow and discuss its limits rather than assuming a feature label answers the question.

Use the review guide to choose the next improvement

Finovifi’s BSA Workflow Review Guide: Where Does the Work Happen? organizes the discussion around six areas: customer and activity context, ownership and handoffs, repeat entry, investigation and decision records, unfinished work, and capacity or support needs.

For each area, identify the existing system or process and mark it as supported, a workaround, needing review or outside the selected scope. These are discussion categories, not compliance ratings. “Our current process supports this well” is a valid outcome.

Use the final page to describe one improvement and what you need to verify next. Do not use the guide to assign live investigations, record findings, make reporting decisions or track case closure. The guide evaluates the work; your approved systems remain where the work is performed and retained.

Where BSA Guardian fits

BSA Guardian supports AML monitoring, customer risk rating, enhanced due diligence, sanctions screening, SAR support and case management. Its case-management capabilities support assigning, reviewing, documenting and closing investigations, while compliance judgment remains with the institution.

Bring your process-level observations to a BSA Guardian demonstration. Ask the team to show how the current product fits your priority workflow, what setup is involved and what remains outside its scope. Existing Guardian customers can use the guide to discuss current product use with Finovifi—not as another form to add to a case file.

When the need is expert guidance, training or policy and procedure resources, BSA Compass offers a different kind of support. It is available standalone or as an optional add-on to BSA Guardian.

Start with the work your team needs to support

Download the BSA Workflow Review Guide for your next internal discussion. Then, when you have a defined technology need, request a BSA Guardian demonstration focused on that workflow.

Bring process questions and desired improvements—not customer information or restricted case materials.

Request a BSA Guardian demonstration

Educational information only. This guide and article are not an audit, a formal risk assessment or a compliance certification. They do not replace independent testing, qualified legal or compliance advice, or institution-approved policies and procedures.