Take a close look at your bank’s BSA/AML training program to ensure staffing levels are sufficient to perform monitoring and investigation activities. Training can be used proactively as part of an institution’s internal controls.
Here are 9 keys for evaluating your bank’s efforts:
1. New Employees
Provide training prior to hitting the trenches.
2. Wide Coverage
All business lines.
3. Specific Training
Tailored to the employee’s specific duties.
4. Comprehensive Training
Not only on BSA and how to identify suspicious activity, but also include bank’s internal policies, procedures, and systems and/or manual processes. Also, don’t forget covering how to escalate suspicious activity to the appropriate department.
5. Train the Experts Too
BSA officers should receive periodic training that is relevant and incorporates current developments, emerging risks/trends, and changes to the BSA and related regulations.
6. Train Board of Directors and Senior Management
They need training to understand the importance of regulatory requirements, ramifications of non-compliance, as well as risks to the bank.
7. Train for Your Tools
Staff utilizing BSA/AML monitoring systems need to be provided with comprehensive and ongoing training to maintain their expertise.
8. Test During Training
This can be an effective method to determine not only the competence of the staff, but also to judge the effectiveness of the training.
9. Document Training Regime, Training Accomplished and Scores of Any Testing
These scores may become useful to judge the effectiveness of any changes
Once you’ve assessed the state of your BSA/AML efforts, you can develop an action plan to ensure you’re addressing the heightened regulatory scrutiny and program risks. Click here to read a “Action Plan to Maintain a Robust BSA/AML Compliance Program.”
A Broadleaf Group Banking Consultant can provide an no-cost assessment of your monitoring and training process. Call 1-866-837-4103 or fill out the form in the right sidebar to get started.
JOIN THE BSA/AML LINKEDIN GROUP
Click this link http://linkd.in/1w9WKP6 to join the BSA/AML Roundtable Networking Group on LinkedIn. This group serves as an online gathering place for banking professionals to discuss a variety of topics including:
BSA/Officers General Role and Responsibilities
Current Regulatory Challenges
Enhancing the Risk Assessment
Enhancing Risk-Based Approaches to AML