Answer:
While some of the technical information that you have to give tellers and loan personnel are probably wasted on IT and HR types, there is no doubt in my mind that IT and HR need some BSA/AML training. IT folks need to know about the systems you use to monitor for, identify, investigate and report on suspicious activity, and how data from each source system feeds into your database. Even if you use off the shelf reports from your systems, your IT people need to know how their work becomes a part of the overall BSA/AML puzzle. They also need to know about requirements that the bank report suspicious activity, so that they can report internally anything they see that might be suspicious: intrusion or hacking attempts, data breaches and thefts, sabotage to systems, etc.
HR personnel may be in a position to learn of an employee's suspect behavior. Perhaps an HR staffer is charged with monitoring or auditing employee accounts. If that staffer learns how to recognize suspicious transactions and the zero tolerance reporting requirement for SARs, HR can become part of the BSA/AML team in your bank. Don't forget to brief HR on the special provision in Section 355 of the USA PATRIOT Act, "31 U.S.C. 5318(g)(2)(B)) allowing the disclosure of information included in a SAR, but not the fact of the SAR filing, in certain written employment references.
First published on BankersOnline.com 6/23/08
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