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AML / BSA Data Quality

BSAfree

Validate anti-money laundering data — SAR/CTR filing timeliness, customer due diligence, beneficial ownership, risk ratings, and sanctions screening per BSA/FinCEN requirements.

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amlbsasarctrcddfincenbeneficial-ownershipsanctionskyc
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About this pack

Data quality checks for Bank Secrecy Act and Anti-Money Laundering compliance. Covers: - SAR filing within 30 days, CTR filing within 15 days - Cash transaction threshold monitoring (>$10,000) - Beneficial ownership capture (>=25% owners) - Customer TIN/SSN format validation - Risk rating population and validity - OFAC sanctions screening flag completeness - CDD refresh timeliness (risk-based) - Suspicious activity narrative completeness Standards: BSA (31 CFR 1010/1020), FinCEN CDD Rule, FFIEC BSA/AML Manual

Sources & References

BSA — 31 CFR 1020.320(b)(3)

SARs must be filed no later than 30 calendar days after the date of initial detection of facts that may constitute a basis for filing a SAR

FinCEN — FinCEN SAR Filing Instructions

Financial institutions must file SARs within 30 days of initial detection, extendable to 60 days if no suspect is identified

FFIEC — BSA/AML Examination Manual - Suspicious Activity Reporting

Examiners verify that SARs are filed timely in accordance with regulatory deadlines

BSA — 31 CFR 1010.306(a)(1)

CTRs must be filed within 15 calendar days after the date of the transaction

FinCEN — FinCEN CTR Filing Instructions

Financial institutions must electronically file CTRs within 15 days for cash transactions exceeding $10,000

FFIEC — BSA/AML Examination Manual - Currency Transaction Reporting

Examiners assess whether CTRs are filed accurately and timely within the 15-day requirement

BSA — 31 CFR 1010.311

Each financial institution must file a CTR for each deposit, withdrawal, exchange, or transfer involving a transaction in currency of more than $10,000

FinCEN — FinCEN CTR Requirements

Aggregated cash transactions exceeding $10,000 in a single business day by or on behalf of the same person must be reported

BSA — 31 CFR 1010.230

Covered financial institutions must identify and verify the identity of each beneficial owner of a legal entity customer at account opening

FinCEN — FinCEN CDD Rule (81 FR 29397)

Beneficial owners holding 25% or more equity interest must be identified and their identity verified

FFIEC — BSA/AML Examination Manual - Customer Due Diligence

Examiners evaluate whether the institution collects beneficial ownership information for all legal entity customers

BSA — 31 CFR 1020.220(a)(2)

Customer Identification Program requires collection and verification of taxpayer identification number for each customer

FinCEN — FinCEN CIP Rule

Financial institutions must obtain a taxpayer identification number from each customer before opening an account

FFIEC — BSA/AML Examination Manual - Customer Identification Program

Examiners verify that the institution collects valid identification numbers as part of CIP requirements

BSA — 31 CFR 1010.210

Financial institutions must establish AML programs that include risk-based procedures for ongoing customer due diligence

FinCEN — FinCEN CDD Rule - Ongoing Monitoring

Institutions must conduct ongoing monitoring to maintain and update customer information including risk profiles

BSA — 31 CFR 501

Financial institutions must screen customers against OFAC Specially Designated Nationals (SDN) and Blocked Persons List

FinCEN — FinCEN Advisory FIN-2010-A008

Institutions must have effective procedures to screen customers against sanctions lists as part of their AML program

FFIEC — BSA/AML Examination Manual - Office of Foreign Assets Control

Examiners evaluate whether the institution screens all customers and transactions against current OFAC lists

BSA — 31 CFR 1010.230(d)

Covered financial institutions must conduct ongoing due diligence including updating customer information on a risk basis

BSA — 31 CFR 1010.230(b)

Covered financial institutions must collect name, date of birth, address, and identification number for each beneficial owner

FFIEC — BSA/AML Examination Manual - Beneficial Ownership

Examiners verify that the institution collects and verifies all required identity information for beneficial owners

BSA — 31 CFR 1020.320(b)(2)

SARs must include a clear and complete description of the suspicious activity including the type, amount, and subject involved

FinCEN — FinCEN SAR Narrative Guidance (FIN-2012-G002)

The SAR narrative is the most critical part of the filing and must provide a clear, complete, and concise description answering who, what, when, where, why, and how

What's included

4completeness rules
3freshness rules
2format rules
1range rules

Checks included (10)

Beneficial Owner Captured(ownership_percentage)

Validates that beneficial owners with 25% or greater ownership interest in a legal entity customer are properly captured. The ownership_percentage must be present and at least 25 when the beneficial_owner_flag is set, per FinCEN Customer Due Diligence (CDD) Rule requirements.

Sanctions Screening Flag Populated(sanctions_screened)

Validates that the sanctions_screened flag is non-null and contains a valid boolean value (true or false) for all active customers. OFAC sanctions screening is a mandatory BSA/AML compliance requirement, and every active customer must have a documented screening status.

Beneficial Owner Identity Complete(owner_name)

Validates that each beneficial owner record contains all required identity fields: name (non-null), date_of_birth (valid date), and identification_number (non-null). Under the CDD Rule, financial institutions must collect and verify these identity elements for each beneficial owner of legal entity customers.

Suspicious Activity Fully Documented(narrative)

Validates that SAR records contain all required documentation fields: narrative (non-empty with minimum 100 characters), activity_type, amount, and subject_name. Complete SAR documentation is essential for law enforcement utility and FinCEN regulatory compliance.

SAR Filing Timeliness(detection_date)

Validates that Suspicious Activity Reports (SARs) are filed within 30 calendar days of the initial detection of the suspicious activity. The filing_date minus detection_date must not exceed 30 days, per FinCEN regulatory requirements under 31 CFR 1020.320.

CTR Filing Timeliness(transaction_date)

Validates that Currency Transaction Reports (CTRs) are filed within 15 calendar days of the reportable cash transaction exceeding $10,000. Financial institutions must electronically file CTRs with FinCEN per 31 CFR 1010.306.

CDD Review Not Stale(last_cdd_review_date)

Validates that the Customer Due Diligence (CDD) review date is not older than the risk-based refresh period. High-risk customers must be reviewed at least annually (365 days), medium-risk every 2 years (730 days), and low-risk every 3 years (1095 days). Stale CDD records indicate gaps in ongoing monitoring.

Customer TIN/SSN Valid Format(tin)

Validates that customer Tax Identification Numbers (TIN/SSN) are present and conform to valid format: exactly 9 digits, not starting with 000, 666, or 9xx prefix (reserved for ITINs in a separate range). This ensures compliance with IRS and FinCEN identification requirements for BSA reporting.

Customer Risk Rating Valid(risk_rating)

Validates that customer risk ratings are populated with one of the allowed values: low, medium, high, or prohibited. Risk ratings are a fundamental component of the BSA/AML compliance program and drive enhanced due diligence, monitoring thresholds, and SAR filing decisions.

CTR Cash Transaction Threshold(cash_amount)

Validates that cash transaction amounts are non-negative and that transactions exceeding $10,000 are properly flagged for Currency Transaction Report (CTR) filing. Under the Bank Secrecy Act, financial institutions must report cash transactions over $10,000 to FinCEN.