By Sarah Murolo | BSA/AML Staff Auditor
As required by the Bank Secrecy Act, all Bank employees should understand the purpose and importance of BSA training. It is believed that continued compliance with BSA helps the Bank build an important weapon against the war on terrorism.
Typically, a standard BSA training should include regulatory requirements as well as the Bank’s internal BSA/AML policies, procedures, and processes. However, the personnel’s role within the Bank determines the depth of BSA training required.
For all banking operations personnel, training should include a general BSA/AML training course that includes the most popular BSA/AML related topics. Specifically, training for tellers should focus on items such as large currency transactions, suspicious activities, etc., whereas training for customer service representatives should focus on customer identification program, suspicious activities, etc. In order to ensure that all banking operations personnel remain up to date with all new requirements and regulations, it is required that training be conducted on an ongoing basis.
It is also required for the Board of Directors and Senior Management to receive BSA training, as it is also recommended that such individuals remain informed of any new developments or changes with respect to BSA related topics. According to the FFIEC, “While the board of directors may not require the same degree of training as banking operations personnel, they need to understand the importance of BSA/AML regulatory requirements…Without a general understanding of the BSA, the board of directors cannot adequately provide BSA/AML oversight; approve BSA/AML policies, procedures, and processes; or provide sufficient BSA/AML resources.” In order to ensure that both the Board of Directors and Senior Management stay up to date with the most current regulations, BSA training is required to be performed on, at least, an annual basis.
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