BSA AML Program Elements Checklist
Record specified AML program evidence against the callers applicable rule version, not a universal checklist certifying BSA compliance. Independently witnessed columns in order: risk-based controls independently documented, independent testing documented, designated compliance responsibility, employee training documented, applicable customer due-diligence provisions reviewed. Missing and unknown remain distinct; this is not legal compliance, coverage, authenticity or safety certification.
Description
An AML program review considers controls, testing, responsibility, training and applicable due diligence.
An AML program review considers controls, testing, responsibility, training and applicable due diligence.1
A checklist records independent documentation without auditing program effectiveness. Use BSA AML Program Elements Checklist to evaluate the supplied inputs under the model explained below.
When to use BSA AML Program Elements Checklist
Use BSA AML Program Elements Checklist to evaluate the supplied inputs under the model explained below. Establish the currency and minor-unit convention, measurement period and applicable transaction or institution context.
How to use BSA AML Program Elements Checklist and understand its results
- Establish the currency and minor-unit convention, measurement period and applicable transaction or institution context.
- Enter Observed criterion flags, Criterion known flags using the field table and validation rules below, then run the tool.
- Read Witnessed Criteria, Known Missing Criteria, Unknown Criteria in the Result object; interpret the units, signs, ordering and unknown-value placeholders described below.
- Correct reported input errors and rerun. Apply successful results according to their specific meanings and check the assumptions before using them in a decision.
| Input field | Meaning | Value type | Requirement |
|---|---|---|---|
| observedCriterionFlags | Observed criterion flags | array of number | Required; constraints below |
| criterionKnownFlags | Criterion known flags | array of number | Required; constraints below |
Enter two binary arrays of exactly five independently annotated criterion flags in the table order: observed presence and whether that observation is known. A known 1 is witnessed, a known 0 is missing, and known flag 0 is unknown regardless of the observation placeholder. Return criterion-text lists in fixed order. This records review evidence; it does not read documents, verify facts or approve compliance.
witnessed=known AND present; missing=known AND absent; unknown=NOT known Use the field order, units and branch conditions described above.
| Criterion index | Independently reviewed criterion |
|---|---|
| 0 | risk-based controls independently documented |
| 1 | independent testing documented |
| 2 | designated compliance responsibility |
| 3 | employee training documented |
| 4 | applicable customer due-diligence provisions reviewed |
| Output field | Meaning | Value type |
|---|---|---|
| result | Object containing the named result fields below. | object |
| result.witnessedCriteria | Witnessed Criteria | array of string |
| result.knownMissingCriteria | Known Missing Criteria | array |
| result.unknownCriteria | Unknown Criteria | array |
{
"input": {
"observedCriterionFlags": [
1,
1,
1,
1,
1
],
"criterionKnownFlags": [
1,
1,
1,
1,
1
]
},
"output": {
"result": {
"witnessedCriteria": [
"risk-based controls independently documented",
"independent testing documented",
"designated compliance responsibility",
"employee training documented",
"applicable customer due-diligence provisions reviewed"
],
"knownMissingCriteria": [],
"unknownCriteria": []
}
}
}Limitations and assumptions
A checklist records independent documentation without auditing program effectiveness. Apply the exact scope and assumptions explained above.
All listed fields require explicit values. Unexpected fields, incorrect types, nonfinite numbers and sparse arrays fail validation. Domain-specific bounds, alignments and supported tokens are explained above; extremely large inputs or outputs can also be rejected. Input errors differ from successful false results, empty match lists and unknown-evidence placeholders.
Alternative or Complementary methods
Use EDD Trigger Checker for a related task: Enhanced due diligence triggers depend on the institution's applicable risk policy.
Use CTR Cash Reporting Threshold Checker for a related task: Cash-reporting review starts with independently linked transaction groups and applicable thresholds.
References
-
BSA AML Program Elements Checklist — tool.io
Similar or alternative tools
- EDD Trigger Checker
Enhanced due diligence triggers depend on the institution's applicable risk policy.
- CTR Cash Reporting Threshold Checker
Cash-reporting review starts with independently linked transaction groups and applicable thresholds.