Banker's Compliance Consulting Blog

BSA/AML/CFT Program Pillars

Written by Kevin Edwards | May 20, 2026 8:31:03 PM

An institution’s BSA/AML/CFT program must incorporate several key components or “pillars”. These are key to the overall structure and function of the program and include the following:

  1. Internal Controls
  2. Independent Testing
  3. BSA Officer
  4. Training
  5. Customer Identification Program (CIP)
  6. Customer Due Diligence (CDD) Program

So, for example, the FFIEC’s BSA/AML Examination Manual states that an institution must ensure that training …cover the aspects of the BSA that are relevant to the bank and its risk profile, and appropriate personnel includes those whose duties require knowledge or involve some aspect of BSA/AML compliance. Training should cover BSA regulatory requirements, supervisory guidance, and the bank’s internal BSA/AML policies, procedures, and processes. Training should be tailored to each individual’s specific responsibilities, as appropriate.

Kevin explains more in the video.

Published 2026/05/20