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.
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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.
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