BSA Training Schedule

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Question:

We are putting together our BSA training schedule. What courses are required annually and what can be done every other year or on an alternative schedule?

Answer:

There is nothing that is required annually or every other year. Training should be ongoing and "as necessary". Look at the following from the BSA Exam Manual:

“Training should be ongoing and incorporate current developments and changes to the BSA and any related regulations. Changes to internal policies, procedures, processes, and monitoring systems should also be covered during training.” [BSA/AML Examination Manual, page 33]

“At a minimum, the bank’s training program must provide training for all personnel whose duties require knowledge of the BSA.” [BSA/AML Examination Manual, page 33]

“The training should be tailored to the person’s specific responsibilities.” [BSA/AML Examination Manual, page 33]

“The board of directors and senior management should be informed of changes and new developments in the BSA, its implementing regulations and directives, and the federal banking agencies’ regulations. While the board of directors may not require the same degree of training as banking operations personnel, they need to understand the importance of BSA/AML regulatory requirements, the ramifications of noncompliance, and the risks posed to the bank. Without a general understanding of the BSA, the board of directors cannot adequately provide BSA/AML oversight; approve BSA/AML policies, procedures, and processes; or provide sufficient BSA/AML resources.” [BSA/AML Examination Manual, page 33]

First published on BankersOnline.com 6/01/09