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RESOURCE CENTER • A FINOVIFI EDUCATION SERIES
Practical insight. Stronger programs.
Practical BSA/AML education for community banks and credit unions, with Finovifi’s BSA Expert Katy Balogh.
Next live session: Ask BSA
What Information Makes a BSA Investigation Easier?
Thursday, November 12, 2026
10:00–10:15 a.m. Central / 11:00–11:15 a.m. Eastern
Submit the specific question or questions you’d like Katy to address when you register.
Start by reviewing how work moves through your institution, then explore the steps in the transaction monitoring process.
BSA Workflow Review Guide
Where Does the Work Happen?
Review one BSA workflow, identify handoffs and see where staff rely on extra tracking or duplicate effort.
Use the guide to focus your next conversation about processes, software, training or support.
Transaction Monitoring Workflow
A step-by-step guide
Explore Katy Balogh’s step-by-step resource, from alert creation and review through escalation, documentation and continuing monitoring.
Use it alongside the review guide to discuss where Guardian can support the work and Compass can support your team.
A practical baseline to tailor to the bank’s risk profile, staffing, systems, and written BSA/AML program.
| Process bubble | What it means for a small bank |
|---|---|
| 1. Alert Created | A monitoring system, employee referral, law-enforcement request, or other source flags activity. Record the alert date for deadline tracking. |
| 2. Initial Triage & Assignment | Confirm the alert is usable, remove duplicates, assess urgency, and assign a trained reviewer. |
| 3. Customer and Transaction Review | Compare activity with the customer profile, expected activity, account history, related accounts, and CDD information. |
| Decision: Reasonable Explanation? | Decide whether the facts explain the activity. A threshold hit alone does not automatically make activity suspicious. |
| 4. Document Decision & Close Alert | If concerns are resolved, record what was reviewed and why the alert was closed. |
| 5. Quality Check / Retain Records | Use risk-based secondary review and retain the alert, evidence, and approval trail under bank policy. |
| 6. Escalate to Case Investigation | Open a case when the alert cannot be resolved or presents higher risk, a pattern, or possible unlawful conduct. |
| 7. Gather Supporting Information | Collect transactions, statements, customer records, prior alerts or SARs, public information, and internal contacts without tipping off the customer. |
| 8. Investigator Recommendation | Summarize facts, red flags, amounts, dates, parties, and rationale; recommend whether to file. |
| Decision: SAR Filing Warranted? | Apply bank procedures and SAR rules to decide whether the bank knows, suspects, or has reason to suspect reportable activity. |
| 9. Document No-SAR Decision | If no SAR is filed, document the basis and approval clearly for independent review. |
| 10. Management/BSA Officer Approval | The designated authority confirms the decision and ensures urgent escalation is handled. |
| 11. Draft SAR & Narrative | Complete known fields accurately and write a chronological narrative covering who, what, when, where, why, and how. |
| 12. Quality Control Review | Check identifiers, dates, amounts, categories, narrative consistency, deadline, and approvals. |
| 13. E-file SAR with FinCEN | Submit through BSA E-Filing, generally within 30 calendar days of initial detection; up to 60 days may apply if no suspect is identified. Save confirmation. |
| 14. Preserve Confidentiality & Records | Restrict access, never disclose the SAR or its existence to the subject, and retain the SAR and support for five years from filing. |
| 15. Monitor Continuing Activity | Continue risk-based monitoring, consider relationship actions under policy, and assess whether later activity requires another SAR. |
Important: SARs are confidential. For activity requiring immediate attention, follow bank escalation procedures and contact the appropriate law-enforcement authority in addition to timely filing. Operational support only; not legal advice.
Practical BSA/AML guidance from Finovifi’s BSA expert Katy Balogh. New briefs appear here as they are published.
Strengthen BSA customer due diligence with five practical checks for expected account activity, risk-based profile updates, and effective monitoring.
Read the brief: Know the Expected Pattern
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