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#1983368 - 12/16/14 05:00 PM AML Training for HR and IT
jhoch Offline
Member
Joined: Nov 2014
Posts: 66
Looking for comments as to whether HR and IT employees should receive AML/BSA training.

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BSA/AML/CIP/OFAC Forum
#1983376 - 12/16/14 05:16 PM Re: AML Training for HR and IT jhoch
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,870
Cape Cod
They may be in a position to see suspicious activity. They won't need to know how to complete a CTR or file a SAR, but they do need to know what to do when they see something that doesn't seem right.
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John S. Burnett
BankersOnline.com
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#1983379 - 12/16/14 05:19 PM Re: AML Training for HR and IT John Burnett
jhoch Offline
Member
Joined: Nov 2014
Posts: 66
Thank you.

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#1983395 - 12/16/14 05:42 PM Re: AML Training for HR and IT jhoch
Pat Patriot Act Offline
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Pat Patriot Act
Joined: Apr 2009
Posts: 450
Insider abuse and computer intrusion are relevant topics for those groups.
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CFE, CAMS

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#1983432 - 12/16/14 07:17 PM Re: AML Training for HR and IT jhoch
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Agreed - there are courses out there that provide a "high-level" overview of the regulation with a focus on Suspicious Activity.

HR and IT don't need to know how to complete a CTR or complete CIP documentation for a new account, but they should be aware of the basic requirements as well as record retention and SAR reporting.

Generally speaking, the type of training you would provide to the Board should be fine for those positions.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#1983816 - 12/17/14 07:07 PM Re: AML Training for HR and IT jhoch
joser Offline
Member
Joined: Sep 2005
Posts: 68
NJ
For HR I include the list of employee RED flags and requiring confidential referrals for employee suspect activity - change of life style, refusal to take vacation, involuntary terminations due to defalcations, embezzlement, theft, bribery, insider abuse, mysterious disappearance and self-dealing. Also thrown in is the purpose of OFAC and why its part of the background check for potential hires.

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