I am looking a good source for BSA AML related training for credit unions? I know that the American Bankers Association has a good frontline compliance course which includes a lot of topics related to BSA (CIP, OFAC etc) but I'm just curious what other credit unions do to comply with NCUA requirements to conduct such training annually?

At my old credit union, I just created a PowerPoint presentation that I would use to train new employees and then the whole credit union annually.

I think under the Banker's Tools there are some samples that you could use as a starting point.

Thank you!

Regardless of where you got your charter or who your insurance company might be, BSA does not make any distinctions between banks and credit unions; i.e. everybody is a "bank."

Please verify that the NCUA has an "annual" training requirement; i.e. find a citation to authority. Their "program regulation" is the same as those adopted by the federal functional regulatory agencies for banks; there is no "annual" training requirement unless it is contained in your own policy.

just Google Bank Compliance Training. You will find a few there. Online services such as BAI, Center for Financial Training, Compliance University.

If you are a smaller shop, then the personal training may be adequate.

If you need outside training, some of the guru's on these threads provide that and I know others who also do training classes.

No matter what, keep attendance records and have documentation of the agenda covered.

Lastly, even though "annual" is not part of the training requirement, it is required to be "ongoing" and I have not found a single examiner or auditor who does not view annual as the industry best practice for training frequency.

I have. Many of them say it's woefully inadequate. They encourage their clients/employers to reinforce more frequent formal training with reminders drawn from the headlines involving money laundering activities and prosecutions. The mythological "annual" training requirement doesn't amount to a panacea.

The only "test" is whether your personnel know what they are required to do...

I think the important part of BSA training at a CU is to make sure that the training is tailored to the job function. If an examiner comes in and finds a lot of BSA issues and it appears that the root cause is "lack of knowledge," they are going to look to your BSA training. Is it adequate? If there are a lot of issues...probably not. I'm not sure how large your CU is, but I would've expected the Board to have training that showed them the basics (plus the implications of non-compliance). BSA Officer (again, depending on size) would have complex training (ACAMS?) and the BSA staff would have training a notch below that. I would expect a BSA internal auditor and/or anyone in Compliance who handles BSA to have some pretty robust training as well.

Here is the comment from NCUA's BSA Questionnaire (you can download the AIRESQuestionnaires from their website)

Appropriate personnel must be trained in applicable aspects of BSA. Training should include regulatory requirements and the credit union’s internal BSA/AML policies, procedures, and processes. At minimum, the training program must provide training for all personnel whose duties require knowledge of BSA. Board members and senior management must also be familiar with the importance of BSA/AML regulatory requirements, ramifications of noncompliance, and the risks posed to the credit union.

Credit unions should document their training programs. Training and testing materials, the dates of training sessions, and attendance records should be maintained by the credit union and be available for examiner review.

While, in my opinion, regulatory oversight is more lax, the training needs of CU's are the same as those for banks. There's no need to emphasize the distinction when there is no difference.

Thank you all for sharing your opinion and thoughts. This helps a lot!

Couldn't agree more.