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BSA Board Training

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Question: 
How in-depth should the training be for the Board of Directors in BSA? Is a general overview of BSA/AML/CIP along with an overview of the procedures in place sufficient for compliance?
Answer: 

This is difficult to answer. It depends on the specific topic, the knowledge and interests of your Board members, your last audit findings, etc. While I don't believe the Board should ever get into the specifics of form completion, CIP details, etc. they should get as much as they want. When I'm asked to provide training for Boards, it always amazes me how "hungry" they are for training and knowledge. Don't assume they don't want training.

The only official guidance we get is on page 33 of the FFIEC BSA/AML Exam Manual:
The board of directors and senior management should be informed of changes and new developments in the BSA, its implementing regulations and directives, and the federal banking agencies’ regulations. While the board of directors may not require the same degree of training as banking operations personnel, they need to understand the importance of BSA/AML regulatory requirements, the ramifications of noncompliance, and the risks posed to the bank. Without a general understanding of the BSA, the board of directors cannot adequately provide BSA/AML oversight; approve BSA/AML policies, procedures, and processes; or provide sufficient BSA/AML resources.

First published on BankersOnline.com 12/10/07

First published on 12/10/2007

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