| Everyone, shared core |
The internal escalation path and how fast to use it, the prohibition on telling a customer a SAR was filed or is being considered, and what to do when a colleague asks them to hold something off the system |
The tipping off failure, which is a personal exposure and the single item nobody should be allowed to get wrong |
| Branch and teller staff |
The currency transaction reporting threshold, how structuring actually looks across a week rather than in one visit, and what to do when a customer asks how to stay under a limit |
Structuring recognized only as a single day pattern, which is how deliberate structuring is designed to be missed |
| Wire, payments, and operations |
Red flags in the payment corridors you actually serve, missing or stripped originator information, and the sanctions screening hit handling procedure |
Speed pressure. Operations staff clear queues, and the red flag has to be recognizable inside that workflow or it will not be |
| Onboarding, KYC, and relationship management |
The customer due diligence steps their role owns, beneficial ownership collection, when enhanced due diligence triggers, and what to do with a customer who will not answer |
Commercial pressure to complete an onboarding with a gap noted for later, which is the most common documented CDD finding |
| Lending and credit |
Source of funds and source of wealth questions, collateral that does not match the stated business, and early payoff patterns |
A team that reads AML as a deposits problem and does not see it in a credit file at all |
| IT and systems staff who tune monitoring |
Change control on alert thresholds, who has to approve a rule change, and why a suppressed alert type is a compliance decision rather than a tuning decision |
The role most often left off the appropriate personnel roster, despite quietly controlling how much the monitoring system sees |
| Board and senior management |
Their own oversight duties, what the reporting they receive is supposed to tell them, and what a program deficiency escalation looks like |
Board training treated as a courtesy briefing with no record, when examiners expect governance level training documented like any other |
| Statutory history and legislative background |
Cap at one item for everyone |
Nobody files a better SAR because they know what year the Bank Secrecy Act passed. This is what generated drafts over produce if you let them |