Skip to content
GeoDataVision
Thread Options
#2254321 - 05/24/21 11:18 PM BSA Training for interns
Secret Squirrel Offline
New Poster
Joined: Jun 2017
Posts: 21
Good afternoon, looking for thoughts on providing BSA training for college or high school interns. Both of these types of interns would not be conducting any monetary transactions.

Thank you

Return to Top
BSA/AML/CIP/OFAC Forum
#2254324 - 05/25/21 11:27 AM Re: BSA Training for interns Secret Squirrel
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,632
Great question, Secret Squirrel. As you probably know, the BSA/AML exam manual says that "training should be tailored to each individual’s specific responsibilities, as appropriate." Therefore, the answer on what training is needed for your interns will depend on their job functions. For example, if they are working in marketing or helping with maintenance, they may not need much more than an overview of who to talk to if they see something suspicious while processing loans or reviewing cash logs would require much different training. The bottom line is that, while they are just short term employees (interns), they still need training that is appropriate for the job they will be doing.

That said, I'm an advocate of every employee (including interns and the maintenance team) getting basic BSA/AML training that provides at least a brief overview of the the purpose of BSA/AML and covers what to look for related to SARs and who to contact if suspicious activity is discovered. So at a minimum, and depending on the job they will be doing, I would at least cover this.
_________________________
Adam Witmer, CRCM

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

Return to Top
#2254336 - 05/25/21 01:21 PM Re: BSA Training for interns Secret Squirrel
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
A different viewpoint, an intern's main role is to hopefully learn as much as they can while there. Why not expose them to BSA and all of it's dark sides, requirements I mean :wink: to give them another view of the many facets of banking?

Return to Top
#2254339 - 05/25/21 01:47 PM Re: BSA Training for interns Secret Squirrel
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,632
I like that one too, PQ. wink
_________________________
Adam Witmer, CRCM

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

Return to Top
#2254360 - 05/25/21 03:54 PM Re: BSA Training for interns Secret Squirrel
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,781
You are here
I would agree but would like to add.

I have seen in policy that "all branch employees must..."

I would also check policy as that may be your ultimate answer.
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2254408 - 05/25/21 08:49 PM Re: BSA Training for interns Secret Squirrel
Secret Squirrel Offline
New Poster
Joined: Jun 2017
Posts: 21
Thank you all for the response. We currently have interns review basic BSA/AML training. Our policy has training is based on your job function.

Return to Top

Moderator:  Andy_Z