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.
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