We supplement online training with live training on BSA and other topics throughout the year.
This is critical. Many of my clients use online training to "check the box" to say that staff had training. However, BSA training is one of the five pillars and this approach may not be adequate. No where in the regulation does is say that training must be annual. It says "Periodic training for appropriate personnel should incorporate current developments and changes to BSA regulatory requirements; supervisory guidance; internal policies, procedures, and processes; and the bank’s products, services, customers, and geographic locations."
Is training effective? I audited a bank that used the same online course every year. The completion records showed me that some employees spent five minutes in the course. Just long enough to click through all the pages and take the same test that they had taken every year. I concluded the training was not effective based on the volume of errors I found in CIP, CDD and suspicious activity monitoring. Online courses are nice to demonstrate general BSA knowledge, but they are no substitute for additional training on bank specific policy and procedures.
Instead of worrying about "passing scores" and "retries" and "tailoring the test so that people pass" make sure that your training is geared to ensure that people know what their BSA responsibilities are for their job function and that their performance demonstrates that they know what to do.
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