Lender Role in the BSA/AML/CFT Program

Lenders typically aren’t involved in the day-to-day recordkeeping and reporting processes of an institution’s BSA/AML/CFT Program. For example, lenders are not going to be tasked with completing a Currency Transaction Report (CTR) and sending that report in to FinCEN. Due to the intricacies of the CTR, that is best left to the experts on the BSA Team. But lenders do need to know what triggers a CTR, what information they might need to collect from a customer and who to ask when they have questions. Lenders play a crucial role in an institution’s BSA/AML/CFT program, it just may look a little different.

Kevin explains more in the video.

BSA Resources!

Published 2026/03/11

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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