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BSA/AML Hot topics: The benefits of annual compliance training

Naomi Glass, AVP, BSA/AML Compliance Officer

Corporate One's BSA/AML webinar series

BSA Latest Information, Regulatory Update and Examiner Focus

October 27, 2:00 – 3:00 p.m.

Geared toward the more seasoned BSA/AML professional, we’ll get you up to speed on the most current industry news and information in just one hour. Topics will include:

  • Member Due Diligence
  • Audit Completion Survival Tips
  • High-Risk Members
  • Suspicious Transactions

One of the most important pillars that must be incorporated into a credit union’s BSA/AML program is training. Training not only stresses the importance of BSA/AML compliance, but it also educates employees on what to do if they encounter potential money laundering and terrorist financing. Training should be conducted on an annual and ongoing basis to ensure that credit union employees remain knowledgeable on BSA/AML-related matters.

By way of a refresher, today’s article reviews three of the major benefits of BSA/AML training.

Meet regulatory requirements.

BSA/AML programs are required to include training for “appropriate personnel.” Almost all employees will fall into this category. Auditors and regulators take this regulatory requirement very seriously and will ask to review documentation to support that the credit union’s staff received the required annual BSA/AML training.

Not only will auditors and regulators request to see a list of employees and board members who received the training and when, but they may also want to review the quiz scores they received if staff/board members were required to take a test at the end of the training. Moreover, auditors and regulators may want to verify that the training content provided to staff members adequately meets regulatory expectations. This can include requests to review the educational materials that were provided to staff, such as training decks, PowerPoint presentations, and quiz questions.

Enhanced detection and reporting of suspicious activity.

Credit unions are tasked with the responsibility to identify and report suspicious transactions involving their members to the Financial Crimes Enforcement Network (FinCEN). As a result, credit unions can serve as the first line of defense in aiding the government’s efforts to combat money laundering, terrorist financing, and other forms of financial crime.

Credit union employees who receive both comprehensive and job-specific (“targeted”) BSA/AML training on an ongoing basis are simply better equipped to be able to detect and report suspicious activity to FinCEN.

Avoid enforcement actions.

Credit unions should be aware that there is a lot at stake if BSA/AML training is found to be insufficient or inadequate, especially if auditors and regulators uncover other significant BSA/AML program deficiencies. When BSA/AML programs do not meet the regulatory requirements, credit unions may be subject to enforcement actions such as cease and desist orders and civil monetary penalties.

How to “stay in the know”

It is critical that credit union employees receive solid BSA/AML training on a continual basis, as well as stay abreast of regulatory updates and news. Fortunately, BSA/AML training comes in all shapes and sizes. It can be delivered to employees via formal, in-person training sessions, e-learning/webinars, emails, newsletters, etc. While it is up to each credit union to decide those methods of learning that are best suited for their personnel, here are some of the regulatory/compliance resources that credit unions should keep in mind:

  • Corporate One’s upcoming BSA/AML compliance training webinar on October 27. Registration is now open!
  • Subscribe to receive FinCEN news updates via email.
  • Access internet resources such as the NCUA’s BSA webpage.