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BSA/AML exam prep: From exam room to boardroom

Terri Luttrell, CAMS-Audit, CFCS
April 28, 2025
Read Time: 0 min

BSA/AML exam prep: From exam room to boardroom

As political shifts influence Washington’s regulatory landscape, financial institutions face new challenges and opportunities. The 2025 administration change has already paused new rulemakings and delayed the effective date of several recent regulations, including those related to anti-money laundering/countering the financing of terrorism (AML/CFT) and the Corporate Transparency Act.

While the tone may suggest regulatory relief, community financial institutions should not interpret this as a signal to ease off their compliance efforts. Instead, institutions should embrace this moment as an opportunity to modernize their approach to BSA/AML exam prep and demonstrate leadership-level commitment to a strong culture of compliance.

 

What does this mean for future regulatory exams?

This perceived reduction in regulatory burden may mean financial institutions will see more flexibility from regulators. Many are asking what will happen to FinCEN’s priorities, and some anticipate that there will be a greater focus on truly risk-based examinations and program effectiveness over technical compliance. But let’s be clear: BSA/AML exam prep still matters.

Changes in tone or examiner staffing do not mean regulators are abandoning core expectations. Institutions must still demonstrate strong internal controls, timely reporting, and a culture of compliance. These must be reflected not just in procedures but also in the actions of leadership and the board.

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Why preparation isn’t just a checkbox

If you’ve been through an exam recently, you know how quickly things can shift from manageable to overwhelming. The first day letter alone can feel like a firehose of documentation requests. However, those who prepare proactively by maintaining current risk assessments, conducting staffing assessments, and documenting clearly and thoroughly position themselves to not only survive an exam but also use it as a meaningful touchpoint with regulators.

Getting ready starts well before that first day letter arrives. Most exam teams give about 2–4 weeks’ notice, but institutions that treat exam prep like a continuous process are more confident when it’s go time.

 

Three steps to stronger BSA/AML and fraud exam readiness

  1. Streamline your foundation by starting with the basics:
  • Are your AML/CFT and sanctions risk assessments up to date?
  • Do you have a fraud risk assessment?
  • Can your team demonstrate timely resolution of alerts, sanctions matches, and SAR filings?
  • Are your policies and procedures current, consistent, and centralized?
  • Do your procedures match actual day-to-day processes?

Even more importantly, do you have the documentation to show all of this? Regulators increasingly expect decisions and alert dispositions to be well-supported. Every case note should read like an examiner might see it, because they will.

Technology plays a significant role here, too. Transaction monitoring software must be optimized based on your institution's risk. Too many, or too few, alerts will draw criticism. Dashboards and automated reports can help reduce the manual scramble when exam or board reporting time hits.

  1. Turn findings into leadership insights

One of the most significant opportunities after an exam is translating technical findings into operational value. When compliance leaders frame issues around the level of risk and impact rather than regulatory language, they engage executives and boards more effectively.

An example of achieving value from a finding may look like this:

  • Exam finding: Greater than 30-day backlog in alert review
  • Compliance insight: Insufficient staff to keep pace with alert volume
  • Leadership takeaway: Time to reassess staffing or enhance monitoring systems

Create a post-exam action plan that clearly defines ownership, timelines, and how progress will be tracked. Following up regularly and tying each item to business impact not only builds accountability but also shows your institution is serious about continuous improvement. Be sure to meet all deadlines in your plan to show commitment to improvements.

  1. Communicate clearly with the board

Boards don’t want technical jargon or data dumps. What they need is a high-level understanding of how the institution is managing risk and where strategic investments may be required. A graph or chart as a one-look understanding of the data will go a long way.

A few statistics to highlight include:

  • Trends in SAR activity by typology, both AML and fraud
  • Alert resolution timelines and backlogs
  • Progress since the last exam, and how findings have been addressed
  • Risk scoring changes linked to customer behavior or product risk

Use visual dashboards or heatmaps to make key points stand out. And always connect metrics to the institution’s strategic risk appetite. That’s what turns compliance from a cost center into a strategic advantage.

Stay ahead with smarter staffing decisions.

Staffing continues to be a hot-button issue and is frequently seen in content orders. Examiners want to know: Is your program appropriately resourced? And just as importantly, can you prove it?

Red flags that may signal the need to re-evaluate staffing:

  • Alerts aren’t reviewed within 2-4 weeks
  • SARs are not filed timely and by the 30-day deadline
  • You’re struggling to clear sanctions hits daily
  • New fraud typologies or regulatory changes have increased your team’s workload

If any of those sound familiar, consider a formal staffing assessment. Tools like Abrigo’s AML staffing calculator can help you model needs based on current and projected volumes—and make the case for additional resources with leadership or the board.

Mock exams: Your secret weapon

Mock exams are one of the most effective ways to strengthen your BSA exam prep. They give you a chance to test documentation quality, evaluate policies and procedures, and simulate interactions with examiners—all before the stakes are real.

Define your scope upfront. Are you reviewing the full AML/CFT program to include sanctions? What about fraud? Will you focus on high-risk customers and enhanced due diligence reviews or look across the board?

Once the mock exam is complete, debrief with leadership. Share where things went well and where improvements are needed. Then turn those insights into clear action items, so your real exam doesn’t come with surprises.

 

What to do right now

Even in a potentially less intense regulatory environment, now is not the time to let your guard down. Instead, use this moment to strengthen your program fundamentals:

  • Align risk assessments with actual exposure, and tie those results to resources
  • Improve documentation practices with the assumption that every decision will be reviewed
  • Simplify your story for the board by focusing on trends, improvements, and what comes next

Purpose-driven BSA/AML exam prep isn’t only about satisfying regulators, it’s about building a resilient, transparent program that reflects your institution’s values and risk appetite. By investing in the right tools, aligning your team with your risk profile, and framing compliance in terms that leadership understands, you’re not just preparing for your next exam; you’re shaping a stronger AML/CFT program for your institution. None of us has a crystal ball, but whether regulation tightens or flexes, proactive preparation will always pay off.

 

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About the Author

Terri Luttrell, CAMS-Audit, CFCS

Compliance and Engagement Director
Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size.

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About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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