An ongoing employee training program is one of the four pillars of a Bank Secrecy Act/AML compliance program, a pillar that continues to attract the attention of bank examiners. Traditionally, AML training was an annual event, usually using third-party provided training modules that provided good coverage of the high-level concepts and requirements of the Act and the regulations and OFAC sanctions requirements.
But those days may have passed. In a risk-based world, everything in the BSA and Sanctions compliance program flows – or should flow – from the risk assessment. Where an institution has identified businesses or customer groups with concentrations of high risk, additional, tightly focused, specialized training is not only appropriate, but increasingly becoming a regulatory expectation. And more often than not, regulators are not only looking for training of the front line employees who process higher risk products or transactions or who interact directly with higher risk customer groups or in higher risk locations. They expect to see all levels of the management structure with control or oversight of these risk concentrations to be sufficiently trained to thoroughly understand the risks under their control and the control structure in place to measure and mitigate that risk. And this expectation rises all the way to the C-suite and the board of directors.
An equally crucial component of the training program is the training provided for new policies and procedures or substantial changes to policies and procedures. A financial institution must ensure seamless transitions from old ways of doing business to the new procedures. There can be no chinks in the control armor.
I will work with the compliance staff, business line management and human resources staff to identify training gaps and the target audience for the training. I am a firm believer in the adage “A picture is worth a thousand words”. And for me, the training “pictures” are small case studies that both get trainees thinking directly about compliance concepts and how to identify them in day to day work and reinforces internal procedures and policy requirements. I will develop training materials tailored to your institution’s methodology and constraints. I have developed from 30 minute computer based modules to day-long classroom training. I have developed and presented executive and board training, where a careful attention must be paid to the level of granularity and tone of messaging.