The following appeared in an FDIC C&D order levied against a Texas bank last year:

(e) The Bank shall implement a training program for all appropriate personnel concerning compliance with the BSA, Financial Recordkeeping, and BSA Programs and Procedures. The initial training shall be completed by .... The Bank shall thereafter conduct additional training on a regular basis, but not less than annually. Employees receiving the initial and subsequent training shall include, but are not limited to, all current or new employees employed by the Bank as tellers, new accounts personnel, lending personnel, bookkeeping personnel, wire transfer personnel, proof personnel, senior Bank management and the Bank's board of directors.


The language certainly is not unique to enforcement actions in Texas, but it underscores the point that the board is very definitely one of your training publics for BSA/AML.

The TBA has asked me to do a presentation at the Senior Management Conference in July that would go toward meeting BSA training requirements for this group. My goal is to do something where, on returning to the bank, your CEO could send the BSA officer a memo indicating which board members attended and attach a copy of the training materials.

I have several ideas for content and structure, but what I need to know from you is: What can I tell them that would help you?

* What examiners are looking for when they do a BSA exam
* The amount of due diligence and record-keeping we are expected to do
* Responsibilities of bank employees (from tellers to the President) because of BSA, CIP and USA Patriot Act
* Reasons why we cannot divulge details of SAR's filed
* What the OFAC list means to the bank (besides the additional work)
* Board oversight of the BSA program --- why they should care
* Reason why the board should elect a qualified employee to serve as BSA Officer...and why that person should report directly to the board...having a good line of communication
* Why they want to stay abreast of BSA changes
* Why they review and approve bank policies annually

That is all I could come up with on the fly....