Hello!

I was under the impression that the BSA Officer needed to be re-approved or affirmed annually along with the BSA Policy and Risk Assessment. However, I cannot find anything that requires this to be done. We are NCUA regulated, so can we appoint or approve the BSA Officer only if there are changes to personnel or should this still be done annually and why?

Thank you

The BSA Officer must be appointed by the Board but there is no requirement that they be re-appointed periodically (unless it says otherwise in your policy).

I agree with Colorado AML that there is just an initial designation requirement, and a specific annual approval is not a rule. That said, many financial institutions do this on an annual basis just because they can. That said, I would check your policy to make sure it doesn't require an annual approval. I doubt it, but there could also be a state law that requires this, so that might be worth checking as well.

Check your corporate organizational documents and talk to your legal counsel. I have seen some chartered banks in which they are required to annually appoint all officers.