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#2200969 - 12/18/18 05:06 PM BSA Staffing
Secret Squirrel Offline
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Joined: Jun 2017
Posts: 21
Is there any guidance/reference to the appropriate staffing you should have for BSA/AML

In todays FinCEN Assessment of AML failurs for UBS they mentioned they failed to provide sufficient resources and inadequate staffing.

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#2200970 - 12/18/18 05:12 PM Re: BSA Staffing Secret Squirrel
Adam Witmer Offline
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I think it depends on many factors such as size, complexity, risk profile, ect. That said, I recently heard someone say the magic number is 1.7 BSA employees per 1 billion in assets - which doesn't sound terrible for an average FI without an extreme risk profile (again - it all depends...).
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2200977 - 12/18/18 06:25 PM Re: BSA Staffing Adam Witmer
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,546
Pulling people out of the ditc...
Originally Posted By Adam Witmer
I think it depends on many factors such as size, complexity, risk profile, ect. That said, I recently heard someone say the magic number is 1.7 BSA employees per 1 billion in assets - which doesn't sound terrible for an average FI without an extreme risk profile (again - it all depends...).


if i were to present this to our senior management, they would probably want to negotiate down to 1.6392839 BSA employee for each 1 billion in assets
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#2200980 - 12/18/18 06:28 PM Re: BSA Staffing Secret Squirrel
rlcarey Offline
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rlcarey
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Posts: 79,672
Galveston, TX
"That said, I recently heard someone say the magic number is 1.7 BSA employees per 1 billion in assets."

There is no magic number - I have been in banks that were $.5B that had 4 staff and they were barely keeping their head above water. It is all a matter of your risk profile. Like snowflakes - no two banks are the same.
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#2200996 - 12/18/18 07:00 PM Re: BSA Staffing Secret Squirrel
RockChucker, CAMS Offline
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Posts: 1,658
The Country
Who you calling a snowflake Randy? wink
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#2201007 - 12/18/18 07:13 PM Re: BSA Staffing RockChucker, CAMS
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,632
Originally Posted By RockChucker, CAMS
Who you calling a snowflake Randy? wink

laugh
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2201100 - 12/19/18 04:41 PM Re: BSA Staffing Secret Squirrel
AMLMGR Offline
Junior Member
Joined: Jan 2010
Posts: 35
You should really base your staffing and assessment of it on whether or not you are completing your work timely in regards to your SLA's. I've never heard my employer or regulator compare our staff size to our assets, but that's a good benchmark to start with if you don't have one. I agree with Adam that risk plays a part in this as well and again, it's risk related to your timeliness of reviewing and addressing the work/input your team is responsible for. Hope that helps!

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#2201267 - 12/20/18 06:59 PM Re: BSA Staffing Secret Squirrel
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,198
New York City
Secret when I joined my shop they had a regulatory finding for staffing. We hired a firm to complete a staffing analysis which supported our decision to hire X number of resources. PM me if you would like their contact information.
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