#1934685 - 06/21/14 03:21 PM
Re: Required experience for BSA Officer
Anonymous
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10K Club
Joined: Oct 2000
Posts: 10,180
Toano, VA
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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.
_________________________
...gone fishing.
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