BSA/AML: Bridging the Gap
Written By: Peter Shea, BSA & AML Consultant
Bridging the gap between the BSA/AML compliance team and front-line teams (i.e., lending, operations, branch customer service and tellers) is one of the most important and most challenging pieces of building a culture of compliance. The front-line is your first line of defense, but without strong engagement and mutual understanding, compliance risks can grow unnoticed. Here are 8 actionable strategies to promote collaboration and ownership across teams:
1. BSA/AML is a Shared Risk
The front line needs to understand not just the what but the why behind BSA/AML rules. This means explaining the risks they help mitigate:
Protecting customers from scams and financial abuse.
Protecting the institution from fines, reputational damage, and being used for illicit finance. Make it real by using case studies directly tied to their roles (e.g., a loan officer missing red flags on a business borrower or a teller overlooking deposit structuring).
2. Build Communication Channels
Strong, two-way communication is essential:
Establish clear, non-punitive escalation paths for staff to report unusual customer behavior or suspicious documents, etc.
In turn, the BSA team should provide quick feedback to reinforce that escalating concerns is important and appreciated.
Appoint a BSA Liaison to attend lending or branch meetings. This puts a face to a name, helping the analyst become the "go-to" partner instead of a "back-office" administrator.
3. Customize BSA/AML Training for Front-Line Staff
Scrap generic compliance training. Deliver role-specific training that applies directly to their function (lending, operations, onboarding, etc.).
Include red flags specific to their products (e.g., misuse of business accounts, third-party payments).
Use real, anonymized internal case examples.
Make it interactive with scenarios, quizzes, and dedicated time for discussion—not just passive slide decks.
4. Integrate Compliance into Business Workflows
Compliance should be frictionless and integrated, not viewed as a burden.
Align procedures with compliance needs (e.g., ensuring the loan origination system prompts for CDD and beneficial ownership data).
Reduce duplicate data entry and build smart forms. Making the process easier benefits both underwriting and BSA teams.
5. Promote Leadership Buy-In and Tone from the Top
Senior leadership must reinforce the tone from the top—compliance is everyone's job.
Include BSA/AML metrics in branch or team performance reviews.
Publicly applaud teams who catch and escalate real risk, not just sales wins.
Use internal newsletters to share success stories where cross-functional teamwork protected a customer or the institution (e.g., stopping a fraud scam).
6. Use Metrics and Provide Feedback
Measure and communicate the impact of the front line's efforts:
Track and share metrics like escalation rates by department and the number of SARs originating from front-line referrals.
Solicit feedback from front-line staff on what is confusing about the process or what would make them feel more confident raising concerns.
7. Normalize Compliance Language
The BSA team must actively translate compliance jargon into plain language during all communications.
Ensure front-line staff understands terms like beneficial ownership, source of funds, layering/structuring, and the difference between unusual (e.g., a large cash deposit) and suspicious (e.g., a structured deposit).
8. Create a Culture of Curiosity
Encourage staff to be curious and investigate anything that "doesn't seem right." Rewarding and integrating reporting into the annual performance evaluation process reinforces its value.
Culture-Building Activities:
BSA Monthly: A quick monthly email or newsletter feature highlighting a case/scenario and how it was caught.
Shadow Days: Have a BSA analyst shadow branch staff (and vice versa) for a morning to build empathy and shared insight.
The Bottom Line: A real culture of compliance is built when everyone feels ownership because they understand why it matters and how it affects their role. The result is front-line and operations staff trust that the BSA team is a partner - not a roadblock simply creating more work for them.
SCA can help you integrate these actions into your BSA/AML program. Contact our Director, Bill Dolan at wdolan@scapartnering.com or by phone at (617) 694-2617 for more information.
