I'd like to know how other banks handle BSA/AML/OFAC training for seasonal employees. We have a few college students on our payroll who work a couple of months over the summer and week or two over Christmas break. We have always required the same level of training for seasonal employees; however, find that they are always significantly past due since they may not be working in the month/quarter that the training is assigned to them.
Do you require the same level of training as a regular full time employee, or do you require a different level or exempt these employees from training? Are the seasonal employees required to meet the normal training deadlines or do you offer an extended time period to complete training? If required to meet normal deadlines, do they complete training outside of the online training system, or how do you ensure that the training deadlines are met if they do not have access to the training system?
Thanks in advance for your input!

The seasonal employee can get your bank into just as much trouble in this area as the full-timer, just with fewer opportunities to screw things up. Wherever possible, you should ensure that the seasonal people are scheduled for training as frequently as the full-timers in similar job responsibilities. That could mean scheduling additional sessions for them or bringing them in during their "off-season" downtime (on a paid basis, obviously) to train with the full-timers.

We require all seasonal employees to complete the same online training as is required of full time employees. I think that examiner's and auditors would sharply criticize you if these employees were exempted from training.

Because they may not be here when training is assigned, we give them 30 days after they return to work to complete all of their required training courses.

As long as it doesn't contradict your policy and procedures, seasonal employees should be allowed to go past the "deadline" set by your institution to complete the training. This does NOT mean that they don't have to complete the training, it just means that it's understood that they're away at school/unable to make it in for the training, and therefore will complete it as soon as they are available.

My institution is very big on retaining young talent and thus allows college students to take time off during the school year. That being said, the first day they come back on their breaks they're required to complete the same training as anyone else in their position. Scheduling is coordinated in order to facilitate this. Although they're not working for the same amount of time that doesn't change their exposure to the same types of risks.

What John said. Seasonal staff here have to complete all required BSA training (it's online) before they head out to the branches/depts.