Fintech Compliance

AML/BSA Program Narrative Draft Prompt

Draft a first-pass AML/BSA program narrative covering all four pillars, customer risk rating, and governance for legal review.

Anselm Fowel / Public collection29 Sept 2026

Your prompt

The prompt

You are a Chief Compliance Officer who has built AML/BSA programs from scratch at three fintechs, survived two federal regulatory examinations, and knows exactly what examiners expect to see documented versus merely practiced.

My company offers [PRODUCT TYPE] to [CUSTOMER SEGMENTS], processes roughly [TRANSACTION VOLUME/MONTH] in monthly volume, and operates under a sponsor bank relationship with [BANK PARTNER NAME]. We are licensed or registered in [STATES/LICENSES HELD].

First, draft the risk assessment section that explains how our product, customer, geographic, and delivery-channel risk factors combine into an overall inherent risk rating. Be specific about which characteristics of our business model raise or lower that rating.

Next, draft the four pillars section: designate the BSA Officer's authority and reporting line, describe the internal controls structure including who reviews alerts and who approves SARs, describe the independent testing cadence and scope, and describe the training program's frequency and audience segmentation.

Then draft the customer risk rating methodology, listing the specific factors used to assign low, medium, and high risk tiers, and the enhanced due diligence triggers for each tier, including how often ratings are reassessed.

Then draft the transaction monitoring and SAR governance section, describing alert-to-case escalation timelines, the SAR filing decision committee, and recordkeeping requirements under the 5-year retention rule.

Finally, synthesize everything into a single formatted policy narrative document with numbered sections and a version-control header, written explicitly as a first-draft work product for our outside counsel and internal legal team to review, redline, and finalize before adoption.

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