BSA Training
Question: I know we have to do training for BSA, but how mandatory is it for back office people, such as operations, lenders, etc. Do they have to be trained annually also?
Answer: You need to answer your own question by asking, where, in your financial institution, can you be in violation of the Bank Secrecy Act? The regulations say we must "...provide training for appropriate personnel..."
At the risk of getting wordy, let me tell you about a training session I was doing in New York City in the early days of BSA. At break time one of the most important lenders of one of the biggest banks in our country came to me and explained that he was there because he was obliged to be. And he realized I had a job to do to educate "...these others." But he wanted me to know he had already taken care of it in his department, because he instructed all the 'junior' lenders to tell all their clients to be sure to keep all their cash transactions under $10,000 so they wouldn't get into trouble. I have to admit, it was one of the few times in my career that I was actually struck speechless!
If I were responsible for BSA training, it wouldn't make any difference if I used videos, or training classes, or other means of communication or education, I would leave no area untouched by BSA training. And I would document who got trained, how they were trained, and when. I would also note who refused to come and why. That should also go into your report to the BOD. The penalties are too great, both personally and corporately, to omit any area of the financial institution.
Copyright © 2004 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 14, No. 6, 10/10
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