What would be the minimal amount of experience acceptable for a BSA Officer position? I know much of this would depend on the size of the bank, products, risk, etc. Just curious how examiners would view a BSA Officer being appointed without previous banking experience and no BSA knowledge or experience aside from the initial BSA training provided through a computer based training course.

When the OCC does their BSA exam, I am required to provide all the training I had since the last exam. Plus I handle all the questions, which can be pretty detailed.
When I was first hired, they had to see my resume, too.

I can't see someone without bank and BSA experience being able to handle the position. But, I may be biased since I feel it takes more than a computer based course to do my job.

Another anon here - at a minimum, the person should be sent for live BSA training right away, possibly BSA professional certification.

I think examiners are expecting BSA Officers to have some certification such as the CAMS certification now.

Anon2 sez: ICBA.
http://www.icba.org/education/index.cfm?ItemNumber=61300&sn.ItemNumber=80126

Poor bankers!

I had zero (BSA) experience, and was two years in before I got any formalized training outside of basic FinCEN webinar type material. But as long as someone has the title, that's all the NCUA seems to care about. If I were ever making a hiring decision though, I'd definitely be requiring experience. Three years in and I'm still learning on a regular basis.

Certifications are meaningless unless you can do the job and then by all means go for the certification.

I would not hire a certified individual with no experience as a BSA/AML Officer no way, no how.

I have been in banking over 30 years and done almost every job that was associated with banking from teller, new accounts to manager. I applied for the BSA/AML position because I know I could do it. I was sent to training to get a certification and now go annually to keep updated. Having my past experience in the other areas of banking helped me a lot. Some of it is just plain common sense and doing all tasks in the best interest of the bank.

As a former BSA Officer for three years, I came in with 30 years of various experience (not in deposits) and was immediately sent for live training and got my CAMS within the first year. However, my lack of branch and deposit experience (incl ACH) hampered me a lot in the beginning and to a lesser extent as time went on. I think the best path up for a BSA Officer is time in a branch and time in Deposit Services, personally--with at least 5 years of experience, more is better. I agree you can overcome the gaps with time and common sense. Not to mention helpful co-workers and management.

The OCC always asks for the resumes of our compliance officer and staff, as well as our internal auditors. They always make comments in the exam regarding their qualifications. I can imagine what their comments would be if one of them had no bank experience and their only training was an online course.

There are no specifically expressed experiential or educational requirements for a BSA officer. You've noted that it is going to be driven by the specific circumstances, but I'll suggest that no experience and no training would only be acceptable in a 1) small institution with 2) a really solid program. A well designed compliance mechanism can coast for a period of time with no one at the helm, but any reviewer is going to expect to see an intense personal effort on the part of the individual and an uninterrupted stream of support from management.

Once upon a time (circa 1990) my former employer decided to automate the filing of CTRs. At the time, the CTR was an important mechanism for reporting suspicious activity...and the feds had very little patience with errors or omissions.

We anticipated (correctly) that the automated aggregation/filing system would reveal previously unreported aggregate transactions, suspicious activity, and false positives. We had to create an important new position to handle the system's output. Based on our volume of filings (50,000 CTRs per year) and the central AML value of the new position, I wrote a beefy description for this clerical job and rated it on a par with a senior head teller at our largest branches. HR (not fully appreciative of the seriousness of BSA) pushed back on my boss--insisting the level should be a grade or two lower. Our response was simple: the person holding this position shielded the bank (in the worst case) from "failure to file" penalties of $10,000 per CTR. 50,000 CTRs X $10,000 penalty = $500,000,000 annual exposure. The position was approved as submitted.

Although a couple of decades have passed, BSA remains a high risk responsibility for banks. All positions relating to BSA should be rated and staffed commensurate with the penalty exposure.

Are BSA officers required to be certified by OCC

No