BSA training for temporary employees

Please share what your FI's position is on BSA AML CIP OFAC training for temporary employees.

As a rule, we don't add temp employees onto the training logs.

We had a unique situation this past year where a FTE terminated employment prior to BSA training being assigned. A few months later, he was asked to work on a temporary basis to work on a special project. He works a few hours a week.

I am thinking I will need to review the job description to see if his assignment touches on any aspects of BSA - ??

would depend on the role they are hired to perform on a temp basis.

we require pretty much anyone other than janitors/maintenance people to go through BSA training because it touches basically every department

Ditto

Every institution I've worked in has required every employee to undergo training. Even security staff...

We also require every employee to do the BSA training.