BSA/AML Frontline Red Flags™ | Free Bank & Credit Union Quick Reference

Would Your Frontline Team Know What to Recognize — and What to Do Next?

Frontline employees are often among the first people to notice unusual transactions, questions, behaviors, or account activity.

But recognizing a red flag does not mean determining that money laundering, fraud, structuring, terrorist financing, or another crime has occurred.

BSA/AML Frontline Red Flags™ is a practical 2-page quick-reference guide designed to help bank and credit union employees recognize potential BSA/AML warning signs and respond appropriately within their assigned responsibilities.

The guide reinforces a simple frontline framework:

RECOGNIZE → DOCUMENT FACTS → FOLLOW PROCEDURE → ESCALATE → KEEP CONFIDENTIAL

WHAT'S INSIDE

Reporting & Recordkeeping Warning Signs

• Questions about avoiding reporting requirements
• Attempts to bypass required identification or records
• Transactions broken into smaller amounts
• Activity conducted across multiple accounts, branches, days, or people

Unusual Currency & Monetary-Instrument Activity

• Unusually large or frequent currency transactions
• Fragmented currency activity
• Transactions near reporting or recordkeeping thresholds
• Unusual monetary-instrument purchases

Unusual Account & Funds-Movement Activity

• Sudden activity in dormant or low-activity accounts
• Rapid movement of funds
• Activity inconsistent with available account information
• Unusually connected transactions, accounts, people, or channels

Identity, Authority & Information Concerns

• Reluctance to provide required information
• Conflicting or unreliable information
• Unclear identity, ownership, control, authority, or relationship information
• Attempts to bypass institutional controls

Scams, Third-Party Direction & Unusual Behavior

• Customers or members being coached
• Pressure to keep transactions secret
• Impersonation and online relationship scams
• Investment and emergency-payment schemes
• Explanations that materially change or conflict with available information

IMPORTANT STRUCTURING REMINDER

A transaction below a reporting threshold is not automatically structuring.

Frontline employees should recognize the facts and patterns, follow institution procedures, and escalate concerns for appropriate review.

WHAT SHOULD THE FRONTLINE EMPLOYEE DO?

Recognize the signal. Report the facts. Let the designated review process do its job.

This resource reinforces that frontline employees should:

✓ Remain professional and avoid accusations
✓ Follow institution-specific BSA/AML procedures
✓ Document objective facts rather than unsupported conclusions
✓ Escalate unusual activity to the appropriate designated resource
✓ Understand the boundaries of their role in SAR decision-making
✓ Protect SAR confidentiality

IDEAL FOR

Bank tellers, credit union tellers, universal bankers, personal bankers, branch managers, teller supervisors, new-hire onboarding, BSA/AML refresher training, fraud-prevention coaching, and financial-institution training teams.

IMPORTANT

A red flag is a reason to pay attention — not proof of money laundering, terrorist financing, fraud, or another crime.

2026 Edition • Version 1.0

Created by Jay Get It™ — Practical Banking Training & Compliance Resources

Educational Use Notice: This resource is a general educational aid and does not constitute legal, regulatory, audit, or compliance advice. Financial institutions should use it alongside their own BSA/AML/CFT program, policies, procedures, systems, approval authorities, required training, and applicable law and regulatory guidance.