Bank Secrecy Act rules and regulations are complex, challenging, and at times, overwhelming. Not only must a BSA/AML professional be able to complete daily tasks like reviewing transactions and filing reports, but they also must be a knowledge expert in the many areas of the Bank Secrecy Act. For this reason, many financial institutions employ professionals who specialize in the Bank Secrecy Act and anti-money laundering rules and regulations.
But what happens when this specialist leaves the financial institution?
Unfortunately, financial institutions sometimes find themselves in a difficult situation when a BSA professional gets promoted or leaves their organization. This is where having continuity in BSA/AML knowledge in a financial institution is important. In fact, the FFIEC BSA Exam manual states that a BSA program should have continuity despite changes in employees. In other words, there needs to be BSA Compliance Officer succession planning. In order to do this, cross-training of employees in BSA & AML rules is essential.
Designating a Back-up BSA Officer
In recent years, there seems to be a growing trend where examiners are starting to expect financial institutions to designate a back-up BSA officer. While there is not a statutory requirement to do this, having a back-up BSA officer can be part of a BSA compliance succession plan and is a good practice, especially for organizations that depend greatly on the BSA officer for day to day BSA functions.
When an organization has a formal BSA succession plan that includes the designation of a back-up BSA officer, the financial institution is able to ensure a smooth transition should the BSA Officer leave or need to take unexpected time off. The challenge with the BSA/AML function of a financial institution is that the clock is always ticking. BSA rules require ongoing report filings with very short deadlines (often just around two weeks), which often does not leave sufficient time to find, hire, and train a replacement.
Therefore, cross-training an employee - such as a back-up BSA officer - in applicable BSA functions can ensure continuity in the event the BSA officer unexpectedly is unable to perform their day-to-day functions.
What Training Does a Back-up BSA Officer Need?
While a back-up BSA officer may not need to understand every single function a BSA Officer does, a back-up should still have a fairly comprehensive understanding of the requirements of a BSA/AML program. The reason for this, of course, is that they may have a minimal amount of time when taking over the function which has complex and strict requirements.
Specifically, a back-up BSA officer should be trained in the foundational elements of BSA/AML rules. This training would generally include areas such as:
A general overview of BSA rules and resources
Currency Transaction Reports (CTRs) & exemptions
Suspicious activity monitoring and reporting (SARs)
Monetary instrument logs (MILs)
Funds transfer requirements (wires)
FinCEN 314(a) searches
A Training Solution for Back-Up BSA Officers
To assist back-up BSA officers in understanding the core BSA/AML rules and expectations, we have created The BSA Bootcamp! Training for Those New to BSA. The BSA Bootcamp! is designed to be a foundational online course on the Bank Secrecy Act and anti-money laundering rules. Longer and more comprehensive than a typical webinar (it runs nearly 3 1/2 hours), this Compliance Class takes a deep dive into the core elements of BSA rules that any BSA/AML professional should know and understand. Using layman’s terms and providing practical examples, this program is both comprehensive and easy to understand, and incorporates a bit of fun into the process. Not to mention a few good money laundering and fraud stories.
While specifically designed as a foundational class those new to BSA, this program would be beneficial for new BSA Officers, BSA Back-ups, auditors, and anyone else with BSA responsibilities or oversight. This program would also be a comprehensive “refresher” for a seasoned BSA professional.
You can learn more about the BSA Bootcamp! in our store here.