Glossary

BSA/AML Compliance Glossary

The terms a compliance team actually uses, defined in plain language by practitioners. For the deeper guides, see the Learn hub.

314(a)

A FinCEN information-sharing process that lets law enforcement query financial institutions, through FinCEN, for accounts and transactions tied to suspected money laundering or terrorism.

314(b)

A voluntary program that lets financial institutions share information with each other, under a legal safe harbor, to identify and report money laundering or terrorist financing.

AML (Anti-Money Laundering)

The set of laws, rules, and controls that detect and prevent the disguising of illicit funds as legitimate income.

Banking as a Service (BaaS)

An arrangement in which a chartered bank lets a fintech offer banking products on the bank's rails and charter, while the bank keeps regulatory responsibility for the activity.

Beneficial Owner

The natural person who ultimately owns or controls a legal entity. US rules generally require identifying any individual who owns 25 percent or more, plus one who exercises control.

BSA (Bank Secrecy Act)

The foundational US anti-money-laundering law. It requires financial institutions to keep records and file reports, including SARs and CTRs, that help detect financial crime.

BSA Officer

The designated individual accountable for the day-to-day operation of an institution's BSA/AML program. A named officer is one of the program pillars.

CDD (Customer Due Diligence)

The process of identifying a customer, understanding the nature of their activity, and assessing the money-laundering risk they present, applied on a risk basis.

CIP (Customer Identification Program)

The minimum identity-verification step at onboarding: collecting and verifying name, date of birth, address, and an identifying number before opening an account.

CTR (Currency Transaction Report)

A report filed with FinCEN for cash transactions above 10,000 dollars in a single business day, aggregated by customer.

EDD (Enhanced Due Diligence)

Deeper scrutiny applied to higher-risk customers, such as PEPs or high-risk geographies. It includes more information gathering and closer ongoing monitoring.

FATF

The Financial Action Task Force, the intergovernmental body that sets global anti-money-laundering and counter-terrorist-financing standards, including the FATF Recommendations.

FFIEC

The Federal Financial Institutions Examination Council, which publishes the BSA/AML Examination Manual that examiners use to evaluate programs.

FinCEN

The Financial Crimes Enforcement Network, the US Treasury bureau that administers the BSA and receives SAR and CTR filings.

Independent Testing

Periodic review of a BSA/AML program by a party independent of the people who run it, to confirm the program is adequate and operating. One of the program pillars.

Integration

The third stage of money laundering, where laundered funds re-enter the economy as apparently legitimate assets or income.

KYB (Know Your Business)

Due diligence applied to business customers, including verifying the entity, its beneficial owners, and the nature of its operations.

KYC (Know Your Customer)

The broad practice of identifying and verifying customers and understanding their activity. In common usage it overlaps with CDD and CIP.

Layering

The second stage of money laundering, where funds are moved through complex transactions to obscure their origin.

Model Risk

The risk of adverse outcomes from decisions based on a model that is wrong or misused. It is managed under SR 11-7, including for AI models.

Money Laundering

The process of making illegally obtained money appear legitimate, traditionally described in three stages: placement, layering, and integration.

MSB (Money Services Business)

A category of non-bank financial business, such as money transmitters and currency dealers, subject to BSA registration and AML obligations.

Money Transmitter

A business that accepts and transmits funds. Money transmitters are MSBs federally and are licensed state by state.

Nested Account

An arrangement where a third party gains indirect access to a bank through another institution's account, often obscuring the true originator of activity.

OFAC

The Office of Foreign Assets Control, the US Treasury office that administers economic sanctions and maintains the SDN list against which institutions screen.

PEP (Politically Exposed Person)

An individual entrusted with a prominent public function, who presents higher corruption and money-laundering risk and typically warrants enhanced due diligence.

Placement

The first stage of money laundering, where illicit cash first enters the financial system.

Red Flag

An indicator that activity may be suspicious, such as structuring, rapid movement of funds, or behavior inconsistent with a customer's profile.

Risk Assessment

A documented evaluation of the money-laundering risk an institution faces across its products, customers, and geographies. It drives the design of the whole program.

SAR (Suspicious Activity Report)

A confidential report filed with FinCEN when an institution knows, suspects, or has reason to suspect activity is suspicious. Its narrative explains the who, what, when, where, why, and how.

SDN List

OFAC's list of Specially Designated Nationals and Blocked Persons. US persons are generally prohibited from dealing with anyone on it.

SR 11-7

The US interagency Supervisory Guidance on Model Risk Management (2011). It is the reference standard for governing models, including AI, through sound development, independent validation, and governance.

Structuring

Breaking transactions into smaller amounts to evade reporting thresholds such as the 10,000 dollar CTR trigger. It is a federal crime in itself.

Transaction Monitoring

The automated and manual review of transactions against rules and behavior to detect activity that may warrant a SAR.

Travel Rule

A BSA requirement that certain information about the originator and beneficiary travel with funds transfers above a threshold. It is increasingly applied to crypto.

Typology

A documented pattern or method of money laundering or financial crime, used to design detection scenarios and red flags.

From terms to a working program

Compliance Command Center turns these concepts into a defensible, examiner-ready program, run by practitioners and leveraged by software.

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