Training Requirements for New BSA Officers
This Compliance Clip (video) outlines the training needed for new BSA Officers. Adam explains that there are five key areas to focus on and concludes with a new resource that can assist in training new BSA Officers. The video with an overview of the BSA Bootcamp, which can be found here.
Video Transcript
The following is a transcript of this video.
This Compliance Clip is going to talk about how to train a new BSA officer. This could relate to somebody who is brand new to BSA or somebody who is a new BSA officer or maybe even a BSA backup or BSA auditor. So the question becomes, what areas should be covered in training for those that are new to the Bank Secrecy Act and Anti-Money Laundering rules?
Well, there's a few things you should focus on.
First of all, it's always a good idea to talk about a history and overview of the Bank Secrecy Act and Anti-Money Laundering laws so that a new BSA officer or even a BSA backup understands their responsibilities under the rules and for your financial institution. It's always a good place to start.
Secondly, it's a good idea to talk about BSA risk and BSA risk assessments. BSA risk should be a foundational component of a BSA/AML program. In fact, BSA risk is so important because it helps you to prioritize everything else you do in your program. The truth is that BSA officers have so many things that they could do that they could have a staff of probably three times what they have still stay busy but the reality is that it's a waste of money to do that much work so BSA personnel have to understand how to prioritize. And you prioritize by taking a risk-based approach. So talking about risk and BSA risk assessments is a good step for training new BSA officers and anybody who's new to BSA.
The next thing that should be covered are the five pillars of BSA. The FFIEC BSA Exam Manual is the main tool that examiners use to examine a bank or credit union on their BSA function. Now, when they come in to conduct a BSA examination, an examiner, regardless of who their regulator is, is going to utilize this uniform exam manual put on by the FFIEC or the Federal Financial Institutions Examination Council. And all that means is all the regulators use this same exam manual to have uniform exams across all agencies. So it's a good idea to understand the five pillars because the five pillars come from this BSA exam manual.
The five pillars include things like board and management oversight, training, customer due diligence or CDD, an independent audit, and things like that. It is important to talk about the five pillars because those are the core pillars of a BSA program.
So we've got the foundation on risk and then we've got the pillars of BSA. Now the next thing that's good to talk about are certain key BSA areas. They kind of fill in all the gaps from the pillars because there are a number of things that have to happen in a financial institution, things like currency transaction reports or CTRs, things like suspicious activity reports or SARs, monetary instrument logs, wire transfers, OFAC searches, customer identification programs, and customer due diligence, etc. There's quite a few key areas, so even though your new BSA officer or any individual who's working in a BSA department may not need to know all of these areas, it's a good idea that they have a general understanding of how the entire function works together so they can know how what they're doing applies to the larger picture of your BSA/AML program.
Finally, it's a good idea to conclude any training for anybody new to BSA with some tips for managing a BSA program. It's always good to point somebody in the right direction and show them some things that they can do to have a really good start when they take over a BSA program or begin to work in a BSA department.
Of course, the Compliance Cohort is offering a program that's designed for new BSA officers and anybody really who is new to the Bank Secrecy Act and any money laundering rules. Our program is called the BSA Bootcamp, and our training includes a number of things. Of course, it's a video training program just like this, but it's actually three and a half hours in length, which is literally the equivalent of two regular length webinars. It's very comprehensive. It's our most comprehensive program to date. It is on demand, so as soon as you purchase this, you have access to this. And it is presented in a virtual classroom approach. So we try to bring the classroom to you. If we were to do a live seminar, this is exactly what it would be like. Hopefully, we wouldn't stand in front of the projector, but we would have slides and we'd be presenting it just like this.
Our program also includes a comprehensive training manual. Now, this training manual is about 67 pages long. It's very in-depth. But we try to narrow it down using layman's terms and easy to understand language so that your employees who take this if it's you or somebody else can just follow along line by line It's simple to understand language and it really becomes proof of content for the examiners So if they ever ask what was trained upon you can hand them the manual and they can see exactly what the training included line by line and not just bullet points but the actual items. It's also good as a reference tool for anybody new to BSA because you can take this with you, you get to keep this electronic manual that we send you and print it out, put notes on it, but you get to keep it and it becomes a reference tool for you at a later time.
Our program also comes with 60 day access. You can download the manual, keep that of course, but you have 60 day access to watch this. You can watch it over and over again.
That is all we have for this Compliance Clip today.