Ask the BSA/AML manual a question in plain words: the verdict first, then the rule beside your own procedure, every sentence cited with its date
Cited BSA answers in under a minute, with your own procedure beside the rule.
See one case, screen by screen ↓BSA/AML Manual Search lets credit union and bank staff ask BSA questions in plain words and get answers from the BSA/AML manual, FinCEN guidance and the institution's own procedures, with the source cited. The verdict comes first, then what the rule says beside what your procedure says, every sentence cited with its date. Eight agents read, ask back, cite and draft; people decide.
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The answer to a teller's question is never in one BSA/AML manual. It is spread across five layers, each with its own date: 31 CFR Chapter X, the NCUA's 12 CFR 748, the FFIEC BSA/AML Examination Manual, FinCEN rulings, FAQs and advisories, and the credit union's own BSA procedures. At the counter, a Member Service Representative phones or emails a BSA team of a few people and waits, while the member waits at the window.
Procedures lag the rules. Norrell's Procedure 6.4 was written in March 2024 and still refers every cash deposit between $8,000 and $10,000, while the SAR FAQs of October 9, 2025 say an amount near $10,000 does not by itself require a SAR. One careless word at the counter can tip off a member, and an answer given by phone leaves nothing to show the examiner what staff were told, or on what basis.
Estimated split of the BSA team's time on one counter question about cash, by hand and with the agents. It leaves out the time the member waits for a call-back. Our arithmetic, kept modest.
Eight agents read the question, ask back the deciding fact, cite the rule and the procedure, and draft the referral; people decide.
Thursday, October 22, 2026, 10:14 am. Jordan Ellery, a Member Service Representative at Norrell Federal Credit Union's Cedar Hollow branch, has a member at window 3. Here is what happens next, screen by screen, in the working solution.
Jordan types: “Member wants to deposit $9,500 cash today and $9,500 tomorrow, do I file a CTR?” The question reader sees a member session open at the window and marks the question member-linked. Before answering, the fact finder stops and asks the one fact that would change the answer, citing Norrell's business day that closes at the 6:00 pm cutoff (Procedure 5.2 §2.1) and 31 CFR 1010.313(b).
“Has this member brought in other cash today, at any branch, ATM or through someone else?” · No other cash today · Yes, there was more · Check the core for me
Jordan presses Check the core for me: no other cash since the 6:00 pm cutoff on October 21. The verdict comes first, at confidence 0.96: no CTR for either day, but splitting cash may be structuring, so refer it. What the rule says (31 CFR 1010.313(b) and 1010.311, the FFIEC manual's CTR section, 31 CFR 1010.100(xx), the SAR FAQs of October 9, 2025) sits beside what Norrell's procedure says (Procedure 5.2 §2.1, v8; Procedure 6.4 §2, v5).
A small note: Procedure 6.4 is older than a source it relies on.
The citation checker read all 11 sentences back against their passages before the answer appeared. Clicking 31 CFR 1010.313(b) opens the passage itself, “Aggregation of currency transactions: multiple transactions”, with the sentence the answer relies on highlighted, the version, where it came from and the copy used, synced at 2:00 am. Opening a passage is logged with the answer.
For a Member Service Representative the answer ends in three steps: accept the deposit as usual, review and submit the referral the agents drafted, and, if the member asks, use only the Procedure 6.7 words. A card says the question is kept in restricted history, seen only by the asker and the BSA team, and nothing goes to the member's account notes, statements or online banking.
“Federal law requires us to report cash over $10,000 in one business day.” Never suggest how to stay under it.
Referral UAR-26-1187, Possible structuring, is marked Restricted. Each fact names its source: Jordan's question, or the core, which shows three cash deposits in the last 90 days, $9,200, $9,600 and $9,450, at Cedar Hollow and Linden Park. The confidentiality guard checks 4 of 4 member-facing systems clear.
Jordan submits the referral as maker. Owen Tillery, a BSA Analyst, accepts it as checker and it opens in case management as REF-26-1187. What the BSA team decides is recorded there and never shown here.
Drafted by the agent · Submitted by the teller · Accepted by a BSA analyst
The procedure watch found that Procedure 6.4, Unusual Activity Referrals (v5, March 14, 2024), is older than the SAR FAQs of October 9, 2025. Its draft PU-26-019 strikes “Refer every cash deposit or withdrawal between $8,000 and $10,000” in favor of a referral only when something suggests the member is avoiding a report, and replaces a full memo for every no-SAR closing with a short statement of why. Each change is cited to the FAQs.
What changes when approved: 37 saved answers to re-check and 1 core banking report to retire.
Marisol Vance, BSA Officer, edits the draft and sends it to the Compliance Committee as maker. Theodore Brandvold, its chair, approves v6 as checker, effective Monday, November 2, 2026. Only then are the 37 answers re-checked and the branches told. The maker cannot approve her own update.
The answer is kept as Q-261022-0418 with the sources as they stood that day, and can be replayed against today's. Helen builds the pack for the NCUA examiner for October 1 to 22: 431 answers with their source versions, 19 referrals with dates and authors only, 2 procedure changes with maker and checker, and 6 disagreements with reason codes. Member names are masked.
The pack never says whether a referral led to a SAR (31 CFR 1020.320(e)).
Five people at Norrell Federal Credit Union who carry one question from the counter to the examiner: what their day looked like, and what it looks like now.
Eight agents read the question, ask back the deciding fact, cite the rule and the procedure, and draft the referral; people decide.
Reads the question, the asker's role and branch, the amounts, dates and who, and marks a question that points at a real member as member-linked.
Finds the one missing fact that would change the answer, asks it in plain words, or reads it from the core banking system with the asker's permission, and shows how the answer changes on the other branch.
Searches 31 CFR Chapter X, 12 CFR 748, the FFIEC BSA/AML Examination Manual and FinCEN rulings, FAQs and advisories by passage, keeping each passage's date and version.
Finds the institution's procedure sections that apply, with version, effective date and owner, and quotes each section's rule in its own words.
Writes the verdict first, then the rule and the procedure side by side, then what to do now, at the depth of the asker's role.
Reads every sentence back against its passage and removes anything the source does not say.
Compares each procedure's date with the sources it relies on, flags a lag, drafts the update as a redline cited to the newer source, and lists the answers and training to re-check.
For a member-linked question, drafts the internal referral from the question and the core, gives only the approved words for the member, and checks account notes, statements, online banking and the contact center's member view for any trace.
Edits updates; the committee approves. The agents propose; a named person decides.
Staff ask from the question box; the BSA Officer can also ask the assistant about the program itself, or tell it what to do. Every answer points to its source.
Which procedures are behind a newer source?
Three of 14. Procedure 6.4 (March 14, 2024) is older than the SAR FAQs of October 9, 2025, and a draft, PU-26-019, is ready for you. Procedure 8.2 still requires 90-day reviews the FAQs no longer require; PU-26-018 is with the committee. Procedure 4.1 still lists reputational risk, which the FFIEC removed in February 2026.
Do we still have to review an account 90 days after a SAR?
The rule no longer requires it; Norrell's Procedure 8.2 still does, until the committee approves the update now waiting for it. Follow Procedure 8.2 until then: PU-26-018 is with the Compliance Committee for October 27.
What has Cedar Hollow asked about cash this month?
Cedar Hollow asked 11 questions in 30 days; 4 were about cash over two or more days, including today's member-linked question, which is masked. The answers are filtered to Cedar Hollow.
Build the NCUA examiner pack for October
The pack covers every answer given in October with the source versions it rested on, the referrals created (dates and authors only, never outcomes), procedure changes with their maker and checker, and overrides with reason codes. Choose who it is for and it is built.
13 screens from the working solution, on its sample data. Pick one to see it large.
How the agents answer, route and keep records are settings. Changes to answer rules, sources and prompts wait for the BSA Officer, and every change is on the audit trail.
| Setting | Default | Choose from |
|---|---|---|
| Confidence threshold | 0.85 | 0.80 · 0.85 · 0.90; below it, the question goes to the BSA team |
| Proposed rules | Shown, never the only basis | Never sole basis · Hide |
| Ask back when a deciding fact is missing | On | On · Off; the fact finder asks, or reads the core with the asker's permission |
| Answer at the asker's depth | On | On · Off; representatives get what to do now, BSA staff the full analysis |
| Mask member names in history, reports and exports | On: initial and last four digits only | On · Off |
| Member waiting | Answer within 30 minutes | Everything else within 4 business hours; escalate to the BSA Officer at 75% of the clock |
| Referral acceptance | 1 business day | A BSA analyst accepts or returns within it |
| Keep answers, referrals and the audit trail | 5 years | The BSA record retention period (31 CFR 1010.430, 1020.320(d)); legal holds set by the BSA Officer |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample credit union data · “target” = the design goal, measured in the live solution · “estimated” = our estimate (the time split for one counter question) · “typical” = published figures (FinCEN: 20.5 million CTRs received in fiscal 2024; FinCEN, Federal Reserve, FDIC, NCUA and OCC: four SAR FAQs issued October 9, 2025). Rules named for context: 31 CFR 1010.100(xx), 1010.306, 1010.311, 1010.313, 1010.430 and 1020.320; 31 U.S.C. 5324; 12 CFR 748; the FFIEC BSA/AML Examination Manual. The credit union, branches, members, people and identifiers named on this page are fictional: characters and sample data in the working solution.
BSA/AML Manual Search lets credit union and bank staff ask BSA questions in plain words and get answers from the BSA/AML manual, FinCEN guidance and the institution's own procedures, with the source cited. The verdict comes first, then what the rule says beside what your procedure says, every sentence cited with its date. Eight agents read, ask back, cite and draft; people decide.
In the sample case, no: cash is added up per business day, and a CTR is due only when one business day's cash in or out passes $10,000 (31 CFR 1010.313(b), 1010.311). Before answering, the agents ask, or check the core, whether the member brought other cash that day. Splitting cash to avoid the report may be structuring, so the answer also tells staff to refer it and drafts the referral.
The rules and guidance are synced nightly, and every passage carries the date of the copy used. A proposed rule is shown as not in force and is never the only basis of an answer. When a new source lands, the procedure watch compares it with every procedure and drafts the update.
The answer says so at the moment of use, with a small note under the procedure. The procedure watch drafts a redline cited to the newer source, such as the SAR FAQs of October 9, 2025; the BSA Officer edits it and the Compliance Committee approves or returns it. Branches are told only after approval.
It is built not to. Member-linked questions are kept in restricted history and masked, the only words for the member come from the institution's procedure, and a guard checks that nothing reaches account notes, statements, online banking or the contact center's member view. Whether a referral led to a SAR never appears, not even in the examiner pack.
Yes. Every answer is kept five years with the source versions it rested on, and can be replayed against today's sources. The audit trail exports a pack for the NCUA or another examiner, internal audit, the supervisory committee or the BSA Officer, with member names masked.
Yes. The agents never file, never decide a SAR, never change a member record and never publish a procedure. The teller submits each referral and a BSA Analyst accepts it; the Compliance Committee approves procedure changes; the BSA Officer approves standard answers, new sources and answer rules. Anyone can disagree with an answer using a reason code.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your BSA procedures, your BSA/AML program and a sample of the questions your staff ask. It goes live once every quality gate has passed. We will walk you through it on your own procedures first.
Every alert read like a short brief, challenged, then closed or escalated in minutes.
1-min demoAML Case ManagementCase files that build themselves, and every SAR call approved by a second investigator.
1-min demoSAR Narrative & FilingSARs drafted from the case and checked three ways, ready for the BSA Officer to sign.
1-min demoWe'll run BSA/AML Manual Search on your own BSA procedures and a sample of the questions your staff ask.