There are 2 very good articles on BSA compliance in the March RMA Journal magazine. One by Ann Jaedicke of the OCC and one by Richard Riese of ABA on risk assessment. The Riese article is especially helpful, discussing actiity where the bank is the target (the bank is the victim), intermediary (bank is the conduit) and abettor (by omission or comission)-you allow it to continue.

Is this accessible online?

they generally make them availalbe online for a fee..I don't know if March is up yet but will check