How to train your organization to achieve BSA/AML compliance

Employee training is more than just a pillar of Bank Secrecy Act/Anti-Money Laundering compliance – it is a fundamental exercise that embeds the regulatory requirements and your company’s risk profile into your organization’s culture and your employees’ roles. As part of your Bank Secrecy Act/ Anti-Money Laundering (BSA/AML) compliance program all financial institutions must provide training for appropriate personnel.

Regardless of your regulator, the guidance provided is the same. More specific guidance is provided in the Federal Financial Institutions Examination Council (FFIEC) Exam Manual which says training should “cover the aspects of the BSA that are relevant to the bank and its risk profile”, and “appropriate personnel includes those whose duties require knowledge or involve some aspect of BSA/AML compliance." As a result of the general guidance provided, many financial institutions have training programs that provide only standard training such as BSA/AML-related definitions and regulatory history. These institutions are missing the opportunity to provide employees with actionable knowledge and could be falling short of regulatory expectations.

Enhancing BSA/AML training to move past providing generic, industry knowledge to a more institution-specific experience, provides a critical risk mitigation control. We are increasingly hearing examiners emphasize that training programs need to be job-specific and customized to your institution’s risk profile, policies, and procedures. This means your bank tellers have different training than your CFO, who has different training than your VP of Retail Lending, and on and on. To ensure your employees and board are properly trained we suggest developing and delivering training programs that use:

• The financial institution’s current BSA/AML risk assessment
• Institution and job-specific policies and procedures
• Transaction monitoring scenarios currently used by the institution to monitor for money laundering and terrorist financing

Providing information and examples that are specific to the institution will allow employees to move past baseline training and progress to training that more significantly resonates with them.