Description

A focused course, tailored for you

AML/OFAC/KYC Exam Defense for Financial Crime Analysts

Build the control documentation, SAR narrative architecture, and OFAC escalation logic an OCC examiner expects to see before the exit memo.

You cleared the alert. You documented the decision. But when the OCC examiner pulls your file six months later and asks why that particular customer wasn't escalated, the written record doesn't tell the story your analyst notes do. The gap isn't your judgment. It's the documentation architecture that should make your judgment legible to an outside reviewer.

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

Most AML/OFAC/KYC analysts operate under a process built for throughput, not auditability. Alerts get cleared with shorthand rationale. OFAC hits get documented with the minimum required to close the ticket. KYC refreshes accumulate deferrals with no explicit risk-tier reasoning attached. This works operationally until an OCC BSA exam, a FinCEN inquiry, or an internal model validation cycle asks: show me the decision architecture, not just the outcomes. At that point, the analyst who built a legible, defensible process is in a different position than one who ran good judgment through a poorly documented system. This course teaches the second type of analyst to build what the first type already has: a documentation and escalation framework that makes financial crime decisions reviewable, defensible, and exam-ready without rewriting everything under pressure.

What you walk away with

Build a SAR narrative architecture that documents escalation decisions in a form an OCC examiner can follow without interviewing the analyst.
Design an OFAC screening workflow with clearing rationale templates that satisfy OFAC's 50 Percent Rule documentation requirements.
Implement a KYC risk-tiering framework that makes refresh deferrals traceable and justifiable under FinCEN CDD Rule review.
Construct a transaction monitoring disposition log that captures the specific reasoning behind closed alerts, not just the outcome code.
Produce an escalation-decision audit trail that functions as standalone evidence in an exam finding rebuttal.
Apply BSA program gap analysis methodology to identify where your current documentation would fail under examiner scrutiny before the exam begins.

The 12 modules

Module 1. How OCC BSA Examiners Actually Read Your Files

Walk through the OCC BSA/AML Examination Procedures document from an analyst's perspective, not a compliance officer's. Identify which fields, narratives, and decision records examiners pull first, how they cross-reference alert dispositions against SAR filings, and what triggers a deeper dive into your individual case files. Build a personal exam-readiness checklist from the actual examination workflow.

Module 2. SAR Narrative Architecture: Writing for the Reviewer, Not the Filer

Most SAR narratives answer the question 'what happened?' OCC and FinCEN reviewers also need to understand 'why this threshold and not lower?' and 'what investigation steps were taken before filing?' This module covers the five-part narrative structure that makes a SAR defensible under cross-examination, with worked examples drawn from common financial crime typologies including layering, structuring, and wire-transfer velocity anomalies.

Module 3. The Non-Filing Decision Record: Documenting Why You Closed the Alert

The riskiest document in any BSA program is the one that doesn't exist: the written rationale for why an alert was cleared without filing. This module builds a non-filing decision record template that captures the specific factors weighed, the red-flag indicators evaluated, and the risk-based reasoning applied. Designed to survive examiner review of your 90-day alert disposition log without requiring you to reconstruct your reasoning from memory.

Module 4. OFAC Screening Workflow Documentation and the 50 Percent Rule

OFAC's 50 Percent Rule extends sanctions obligations to entities owned 50 percent or more by a blocked person, even if those entities aren't on the SDN List. This module covers how to document your screening workflow, your ownership-structure investigation steps, and your clearing rationale in a format that satisfies OFAC's recordkeeping expectations. Includes a clearing decision template for common false-positive scenarios: name similarity, transliteration variants, and shared-address coincidences.

Module 5. Escalation Logic: Building the Decision Tree Your Compliance Officer Signs Off On

Escalation thresholds that live in an analyst's head are a program liability. This module covers how to externalize your escalation criteria into a documented decision tree that your compliance officer can formally adopt as written procedure, your manager can supervise against, and your OCC examiner can evaluate as evidence of a risk-based program. Includes threshold calibration methodology for alert volume, transaction type, and customer risk tier.

Module 6. KYC Risk Tiering: Making Refresh Deferrals Traceable Under CDD Rule Review

FinCEN's CDD Rule gives banks flexibility on KYC refresh timing based on customer risk tier. That flexibility only holds under examination if the tier assignment and deferral reasoning are documented. This module builds the risk-tiering framework and the refresh-deferral justification template: what factors move a customer between tiers, what events trigger an out-of-cycle review, and how to document both so FinCEN examiners can follow the logic without supplemental memos.

Module 7. Beneficial Ownership Documentation: The CDD Rule Gap Most Analysts Inherit

The Legal Entity Customer certification workflow was designed by compliance, but the documentary gaps tend to show up in analyst-level case files. This module covers how to identify missing or stale beneficial ownership certifications in your active book, how to document outreach attempts and responses in a form that satisfies the CDD Rule's five-year recordkeeping requirement, and how to flag material changes in ownership structure that should trigger a fresh certification rather than a refresh.

Module 8. Correspondent Banking and Wire Transfer Red-Flag Documentation

Wire transfer velocity, nested correspondent accounts, and shell-company beneficiaries are the three typologies most likely to generate OCC findings in a transaction monitoring program. This module covers the specific documentation each typology requires: the velocity-threshold rationale for monitoring rules, the nested-account investigation steps when a correspondent bank is in the originator chain, and the beneficial-ownership research pathway for beneficiaries with opaque corporate structures. Each section includes a case-file template.

Module 9. Model Validation Readiness: What Your Transaction Monitoring System Actually Needs to Document

OCC Supervisory Guidance on Model Risk Management (OCC 2011-12) applies to transaction monitoring systems. When your bank's model validation team reviews the TM system, they will pull analyst dispositions as evidence of model performance. This module covers how to write dispositions that serve both operational and model-validation purposes, how to identify and document false-positive patterns that should go to your model governance team, and how to structure your contribution to the annual model performance review.

Module 10. Internal Audit Interface: Responding to BSA Audit Findings at the Analyst Level

Internal audit BSA reviews generate findings that land on compliance officers, but the remediation evidence often comes from analyst-level documentation. This module covers how to read an audit finding from an analyst's perspective, how to identify which of your case files the finding implicates, and how to build the corrective documentation without overhauling your entire workflow. Includes a response-to-finding template that maps each corrective action to a specific case-file or procedural change.

Module 11. BSA Program Gap Analysis: Finding Your Documentation Weaknesses Before the Examiner Does

Exam preparation is more effective when it starts with a gap analysis from the analyst's own file review rather than from a top-down compliance review. This module provides a self-administered gap analysis framework: which file types to sample, which documentation elements to check against OCC examination procedures, and how to prioritize remediation effort when you have limited time before the exam window opens. The output is a personal remediation checklist, not a program-wide policy document.

Module 12. Building Your Exam-Ready Documentation System as a Practitioner

The final module integrates the previous eleven into a practitioner-level documentation system you can implement within your existing case management tools, whether that is Actimize, Mantas, NICE Actimize, or a home-built workflow. Covers how to standardize your personal templates across SAR narrative, OFAC clearing, KYC tiering, and alert disposition, how to calibrate the system to your specific analyst workload, and how to maintain it without adding significant time to each case close.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

You closed an OFAC alert with a one-line note and now an examiner wants the ownership investigation documentation. Module 4 covers exactly this: building clearing rationale that satisfies the 50 Percent Rule without reconstructing from scratch.

Your SAR narrative makes sense to you but your compliance officer can't defend it to FinCEN without calling you. Module 2 teaches the five-part narrative structure that makes the SAR self-explanatory to a reviewer who wasn't present for the investigation.

A KYC refresh backlog has accumulated and you have six deferred cases with no documented risk-tier reasoning attached to the deferrals. Module 6 builds the tiering and deferral justification framework retrospectively and prospectively.

Internal audit flagged your alert disposition documentation as insufficient and you are not sure what 'sufficient' looks like at your volume. Module 3 and Module 11 together address the non-filing decision record and the gap analysis framework.

What you get with this course

Twelve written modules built for the financial crime analyst role, not the compliance officer role.
Downloadable templates for every core documentation type: SAR narrative, OFAC clearing decision, KYC risk-tier assignment, non-filing disposition record, escalation decision tree, and BSA exam gap analysis checklist.
Worked case examples for common typologies: structuring, layering, wire-transfer velocity, nested correspondent accounts, and beneficial-ownership opacity.
A hand-built implementation playbook tailored to your BSA program configuration, delivered alongside course access within 24 hours of enrollment.

What you will have in hand by Day 1, Week 1, Month 1

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.

Before and after

Before

Your alert decisions are sound, but your paper trail reflects throughput logic: minimum documentation to close the case. When an OCC examiner or internal auditor asks why a specific case went one direction rather than another, the answer exists in your professional judgment but not in the file.

After

Every category of decision you make, from OFAC clears to SAR non-filings to KYC deferrals, has a written rationale structure that makes your judgment legible to a reviewer who reads the file cold. Your documentation system functions as exam-ready evidence without requiring you to reconstruct anything under pressure.

What happens if you do not address this

BSA examination findings at the analyst level typically trace back to documentation gaps, not to bad judgment calls. An analyst whose documentation architecture cannot survive an examiner review will eventually need to remediate under pressure, often mid-examination, which produces inconsistent and retrospectively constructed records. The cost of building a defensible documentation system before an exam is several hours of practice. The cost of building it during one is much higher.

Who it is for

Financial crime analysts at US regional and national banks, credit unions, and broker-dealers who handle transaction monitoring, OFAC screening, SAR filing, and KYC onboarding as part of a BSA/AML compliance program. Typically 1-5 years in role, running established processes but not yet owning program architecture. Facing OCC, FDIC, or FinCEN examination cycles and recognizing that their personal judgment is sound but their paper trail isn't exam-grade.

Who this is NOT for. Compliance officers at the program-ownership level who already write BSA policies. Analysts at non-bank fintechs where OCC examination is not the primary regulatory pressure. Anyone looking for a refresher on the regulatory rules themselves rather than the documentation and escalation architecture that makes those rules auditable.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable templates and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Approximately 8-12 hours across the 12 modules, plus additional time to apply each module's template to your current case files. Most analysts complete the core modules in two focused sessions and implement the documentation system progressively over the following two weeks.

Why $199 is the right number

OCC examination prep courses aimed at compliance officers teach program design and policy writing. FinCEN guidance documents describe what is required but not how to build the analyst-level documentation that satisfies it. This course is the practitioner-level build: templates, decision frameworks, and worked examples for the specific file types an analyst produces every day.

FAQ

Does this course cover a specific transaction monitoring platform like Actimize or Mantas?

The course is platform-agnostic. The documentation architecture and decision frameworks apply regardless of which case management system you use. The implementation playbook will account for your specific platform's documentation fields.

Is this relevant if my bank's next OCC exam is more than a year away?

Yes. The best time to build a defensible documentation system is before exam pressure exists. The gap analysis module helps you find and close documentation weaknesses on your own timeline rather than an examiner's.

Does this cover BSA requirements outside the US, such as UK or EU AML rules?

The course is built around OCC, FinCEN, and US BSA/AML regulatory expectations. The SAR narrative and KYC frameworks have structural parallels to MLRO reporting and CDD under AMLD, but US regulatory terminology and examination procedures are the primary frame of reference.

How is the implementation playbook tailored to me specifically?

Gerard reviews your role, institution type, and current BSA program context from your enrollment and builds a playbook that maps the course frameworks to your specific situation, including which templates to prioritize, which modules apply most directly to your current examination exposure, and how to sequence implementation.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.