New Hire Training

I remember a regulator dinging us because the tellers and other customer service areas did not have BSA training prior to hitting the floor. Looking in the BSA/AML Manual I can only find this:

"In addition, an overview of the BSA/AML requirements typically should be given to new staff during employee orientation."

I am having trouble finding something saying that they have to have BSA training during orientation. Can you help?
Thanks.

All of our new employees receive BSA training within 30 days of hire. We've been examined 3 times since I started here and this has never been an issue with the FDIC.

You referenced the verbiage from the BSA/AML Manual. That's a very strong point of reference. I would opine that should suffice in most, if not all cases.

I would like to see someone put a teller on the line without BSA/AML training for 30 days and try to defend it.

In other words...how can you demonstrate that your teller knows to looks for structuring, or what information to gather if a CTR is required, or if a monetary instrument is sold in excess of $3,000 in cash, and a host of other reasons.

We do ours during their training period. I agree with BrianC, what if they have one of these reportable transactions or suspicious activity? There is no way I would put someone on the teller line without at lease an overview of BSA and what their responsibilities are.
I don't think you are going to find something that says you have to train during orientation because not everyone has orientation. But the idea is that you don't let them have their drawer and interact with customers until the BSA training has been completed.

I didn't mean to say that the tellers didn't receive ANY BSA training for 30 days. They have 30 days to complete the on-line training course that I assign. They certainly are introduced to BSA during the side-by-side training they receive in the branch before they are put in a window.

Well, you didn't. But that is what the original poster said the regulators were dinging them for........