Thread Options
#2092359 - 08/09/16 05:34 PM BSA training specific to job function
Tabbetha, CRCM Offline
Junior Member
Joined: Feb 2009
Posts: 44
Mississippi
How are banks training employees on BSA/AML specific to job function. Does anyone have documents or power point presentations they can share?

Return to Top
BSA/AML/CIP/OFAC Forum
#2092423 - 08/09/16 09:22 PM Re: BSA training specific to job function Tabbetha, CRCM
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,639
The Country
I believe I saw some options in the Tools section on this website.

We use a service that has created courses for Tellers, CSRs, Loan Officers, Operations, Board Members etc.

Good luck!
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2092437 - 08/10/16 11:52 AM Re: BSA training specific to job function Tabbetha, CRCM
thomasj Offline
Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
BSA/AML training is one of those things that will always be low hanging fruit for auditors and examiners. Over the past 16 years, I have tried seemingly every approach and no matter what you do, it seems that someone will have an issue. I was going with full blown, ground up, all inclusive training for every employee of the bank, right down to our couriers thinking that we were covered even though in many cases it was overkill. No. An auditor had a criticism that the training was not job specific, even though everyone was getting more training than what applied to their jobs. So I switched gears and assigned job specific training courses and was criticized by an examiner because some back office staff weren't trained on some topic unrelated to their position. I've tried to maintain a middle ground now with an intermediate BSA/AML course online and then speaking to certain groups (New accounts personnel, tellers, branch managers, operations) at their department meetings regarding topics specific to them. With this approach, I've been criticized for insufficient documentation of topics discussed and lack of attendance sheets. I'm sure when I correct those issues, I will be criticized because Sally was on vacation when I spoke at the teller meeting and I have no documentation that she received the information.

We train mostly by using online courses - it's become a necessity with 500 employees spread across 3 states. The courses are professionally done, cover the required content, and it gives us a great audit trail of who has taken the course, test scores, and so forth. I'm now getting heat from examiners stating that online training is OK for the new employee but that I need to be doing face to face training for existing employees. As soon as they figure out this whole cloning thing, I will get right on that.
_________________________
Knowledge is knowing what to say. Wisdom is knowing when to say it.

Return to Top
#2092440 - 08/10/16 12:09 PM Re: BSA training specific to job function thomasj
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
BSA/AML training is one of those things that will always be low hanging fruit for auditors and examiners.


True, specifically because:
1) it's a legal requirement,
2) everyone has an opinion, and
3) it's good filler where no substantive problems have been found.

If, in my judgment, the training program is adequate, my response to third party criticism would be that, in the absence of specific anecdotes where employees did not know what they were supposed to do, I believe that our training is both adequate and compliant with our policy.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z