---
title: BSA Regulation and Fraud: Bridging the Gap, with Nyla Cortes
source_page: https://www.sardine.ai/media/fraud-forward/episodes/bsa-regulation-and-fraud
canonical: https://www.sardine.ai/media/fraud-forward/episodes/bsa-regulation-and-fraud
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date: 2026-11-11T13:01:00.000Z
description: BSA regulation and fraud teams often work in silos. Why working together on Reg E claims, elder exploitation referrals, and policy ownership protects members…
---

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# BSA Regulation and Fraud: Bridging the Gap, with Nyla Cortes

**Published:** 2026-11-11T13:01:00.000Z

BSA regulation and fraud teams often work in silos. Why working together on Reg E claims, elder exploitation referrals, and policy ownership protects members…

What’s up fraud fighters, and welcome back to Fraud Forward!
This one is extra special. We are live at Money 2020, and I am sitting across from Nyla Cortes, my former desk mate from our credit union days. Back then, we co-hosted a podcast called THE TEA, which stood for training, education, and awareness. Our goal was to turn compliance and fraud jargon into real world understanding, and that is exactly what we do again today.
Nyla knows BSA and consumer protection regulations inside and out. I know the fraud side. In this conversation, we talk about what happens when those two worlds stay siloed and what changes when they start talking. We look at an elder financial exploitation case that taught me why a policy exists, play a game of fraud or compliance, and get into Reg E claims, cash activity, and who should own the gray areas. If you have ever wondered how BSA regulation and fraud fit together, this one is for you.
Stay until the end, because Nyla has some news she wanted to share here first. Let’s get into it.
What you’ll hear in this episode:
How a BSA team and a fraud team handled an elder financial exploitation case together, including the adult protective services referral and the unusual activity referral that let fraud act.
Why siloed BSA and fraud teams create double work, and how better communication between a BSA officer and a fraud team fixes it.
What bridging the gap between BSA and fraud means in practice, and why friendship is not required.
How Reg E claims, provisional credit timelines, and the 10 day and 45 day investigation window protect members and institutions.
Why unauthorized transfer claims need both a compliance clock and a fraud investigation.
What to do when one device logs into a dozen accounts in an hour.
Who owns money that comes in and goes straight out with no clear purpose, and why policy has to decide.
What happened when a member walked in with $30,000 in cash, and how CTR filing fits into the bigger picture.
Why explaining regulations in plain English helps fraud and compliance teams work together.
You should listen to this episode if you:
Work in fraud and want to understand why BSA cannot always let you act right away
Work in BSA or compliance and want better communication with your fraud team
Are a compliance officer or analyst new to BSA and want regulations explained in plain English
Work at a credit union or community bank and handle Reg E claims
Are deciding who owns a gray area like money in and out with no clear purpose
### Episode notes
The elder exploitation case that showed me why the rule exists
Nyla asked me to name a moment in my career when someone made the rules feel clear. I told her it was her. We were working an elder financial exploitation case, and at our credit union that kind of case went through BSA first. I am a fraud person, and I wanted to step in right away. I could not understand why I had to wait. Nyla explained the policy and promised to send me an unusual activity referral once BSA had contacted adult protective services. That mattered because the account was still open and still being used, and BSA could not touch it. Fraud could. The referral also meant it would not land in a box where maybe a SAR gets filed and maybe it does not. Once I understood why the rule existed, I stopped arguing with it and started using it.
Bridging the gap between BSA and fraud
Nyla says BSA and fraud teams are still two separate groups with very little conversation. In cases of elder financial exploitation or identity theft, the work crosses over. Without conversation, everyone does double work, and nobody wants that. Bridging the gap between BSA and fraud was our slogan back then. I think we had an advantage because we liked the person behind the process first, and not every team gets that. Nyla’s reminder is that friendship is not required for collaboration. If you learn to speak the other person’s language, you can build the bridge.
Reg E, the clock, and why compliance is a member win
For our game, I gave Nyla a scenario. A customer files an unauthorized transfer claim, saying they never authorized it. Nyla says Reg E claims run on a clock. Compliance watches the notices and whether provisional credit goes out on time. Fraud watches the investigation, the patterns, and whether a merchant is doing the same thing to other customers. I like that the 10 day investigation and the 45 day deadline protect the member while they protect the institution. They can also show where a team is stretched. If three people face 50 cases a day, compliance can advocate for more resources or new technology. Nyla reminded me that Reg E is a consumer protection law built to keep banks from wronging the consumer. Compliance is not tattling. It is a cultural win.
One device, a dozen accounts, and what compliance means
Our next scenario was one device logging into a dozen accounts in an hour. Nyla’s answer was both. Fraud spots it and tracks the pattern, and compliance wants to know whether it ties to something bigger. I added that compliance needs to hear about it to understand the risk of the product. The team may also need to ask whether current processes allow anyone to interrupt it. That can bring in the payments team and even the vendor relationship, with a simple question about whether the vendor can catch it. We also clarified what we mean by compliance. Nyla says it can include BSA, risk, and sometimes fraud, depending on how an organization is built, along with regulatory compliance, consumer protection compliance, and lending compliance.
Money in, money out, and who owns the gray area
The last scenario was money that comes in and goes straight back out with no clear purpose. Compliance sees monitoring and fraud sees mule risk. Nyla says the answer comes down to policy. Your BSA policy or your fraud policy has to say who owns it, and both teams may hold the torch because it is a different risk. I remembered a member who walked in with $30,000 in cash in his pocket. I wanted to call law enforcement, and Nyla said no, because we needed to understand the pattern first. The transactions were authorized, which meant there was no technical fraud. The next step was to identify the pattern and report it, including the CTR filing for cash deposits on the BSA side. I realized I was looking at one account at one institution and not the broader picture. If we help law enforcement or regulators connect pieces on their side, we are doing our part.
Explaining the rules in plain English
Nyla has a gift for explaining regulations in plain English. When I had to go back to what a reg actually said, I would ask her, because reading it myself felt like translating Greek. She walked into compliance 11 years ago, and she says it can be intimidating for anyone new, especially the compliance officer who is expected to explain it all to the rest of the company. That is why a clear explanation matters to people in fraud, BSA, and compliance for credit unions. When one team can explain the why to another, the rules stop feeling like a gray box.
### Key takeaways
Fraud and compliance teams working together prevents double work, especially in elder financial exploitation and identity theft cases.
Understanding why a rule exists makes it easier to work within it, as in a policy that sends elder exploitation through BSA first.
An unusual activity referral from BSA can give fraud the chance to act on an account that BSA cannot touch.
Collaboration does not require friendship, but it does require learning the other team’s language.
Reg E claims run on a clock, and compliance tracks notices and provisional credit timing while fraud investigates patterns.
Reg E is a consumer protection regulation that protects members, and it can also show when a team needs more resources.
When one device logs into many accounts, both fraud and compliance need to know, and the vendor relationship may be part of the answer.
Compliance can include BSA, risk, consumer protection, lending compliance, and sometimes fraud, depending on how an organization is structured.
Money that comes in and goes straight out needs a policy that says who owns it, because fraud sees mule risk and compliance sees monitoring.
Authorized transactions are not technical fraud, and identifying and reporting the pattern helps law enforcement connect the pieces.
### Final takeaway
The best way to bridge BSA regulation and fraud is to explain the why. A rule that feels like a roadblock becomes a plan once you understand the reason behind it, and a gray area becomes manageable once your policy says who owns it. Nyla and I learned that by working side by side, and I think any fraud and compliance team can learn it too. Start with one referral, one shared scenario, or one conversation about the clock. The members you protect will feel the difference.
Episode resources & links
Want more fraud fighting in your inbox? Subscribe to The Monday Fraud Fix. My weekly newsletter with the trends, stories, and takeaways I’m paying attention to. Subscribe here.
Connect with Nyla Cortes, CBSAP | LinkedIn
Community Lead for Compliance at Sardine
Bank Secrecy Act Compliance Specialist (BSACS)
Credit Union Enterprise Risk Management Expert (CUERME)
Translating AML and Regulatory Compliance into plain English
Financial crime, consumer protection, fair lending, mortgage rules, fraud and scams
Subscribe to the Regulated newsletter
Connect with Hailey Windham, CFCS, CUERME | LinkedIn
Host of the Fraud Forward Podcast
Banking Community Lead at Sardine
Certified Financial Crimes Specialist (CFCS)
2023 Credit Union Rockstar, CU Magazine
Continuous Improvement Award, SAFE Federal Credit Union, 2023
Top 20 Professionals Under 40, The Sumter Item, 2022