Answer:
Although it's apparent that the bar keeps being raised on this issue, in that regulators are raising their expectations, everyone in the organization should have some BSA training. Well, perhaps you can exempt the building custodian. This training can be general enough to provide a basic understanding about the purposes of BSA and AML laws, and the bank's and employees' roles in complying with the rules. Things like suspicious activity need to be discussed.
That said, much of BSA training should be targeted to the specific audience. Tellers obviously have unique responsibilities; their training needs to be unique. Lending staff should get information about money laundering and loans and suspicious activity in their niche of the bank. Everyone needs to understand your CIP program if they open or manage customer accounts. There should be unique training for your private bankers and/or trust and investment folks.
Summing up, each person on your staff should understand his or her role in complying with BSA/AML rules.
First published on BankersOnline.com 9/20/04
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