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6 Steps to build an AML staffing plan for unexpected changes

Terri Luttrell, CAMS-Audit, CFCS
February 14, 2024
Read Time: 0 min

Planning for the unexpected is part of any good plan.

Prepare for unexpected changes in your AML staffing plan, making your plans a little more "disaster" proof.

You might also like this on-demand webinar, "AML/CFT hot topics for 2024: What to expect for financial crime."


Anti-money laundering compliance

6 Steps to build an AML staffing plan for unexpected changes

Prepare for unexpected changes in your AML staffing, whether related to the Bank Secrecy Act (BSA) Officer retiring or a key staff member going out on leave, departing for a new opportunity, or going on vacation. 

Planning now will mitigate the compliance risk from turnover and reduce stress for you and your AML program during times of change. It helps financial institutions avoid or at least plan for financial impacts tied to sudden staffing shifts. 

 Identify crucial AML staff positions and processes

  • What tasks are critical to daily operations? 
  • What tasks are required per regulations? 
  • Who performs those tasks? 
  • How often are they performed? 
  • Are there multiple people assigned to projects or tasks to share responsibilities? 

Assess key talent for AML needs

  • Review current roster. 
  • Review current workloads of relevant employees. 
  • Inquire directly with employees. 
  • Find cross-training opportunities. 
  • Identify all potential backups. 

Incorporate professional development

  • Interview each employee. 
  • Gauge interest in/willingness to take on other tasks/roles. 
  • Identify who is ready now to add tasks/roles vs. who needs additional training. 
  • Document who can do what if roles need to be adjusted unexpectedly. 
  • Cross-train and develop staff. 

 Anticipate possible triggers of AML staff changes (institution-specific)

  • Promotions. 
  • Terminations/resignations. 
  • Leaves of absence. 
  • Vacations/sabbaticals. 
  • Regulatory changes affecting your program. 
  • Major institutional realignments that could affect available backup resources. 

Know the red flags for money laundering. This AML investigations checklist can help.

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Use results from above to document and approve AML succession plan

  • Scout key AML positions/talent. 
  • Watch for triggering events. 
  • Build out and document plans to remain BSA compliant. Include HR to add steps for replacing staff. 
  • Submit plans to AML program executive management for approval. Share with the board, which must appoint any interim or new officer when a BSA Officer leaves/requires an extended absence. 
  • Amend as needed. 

Activate the staffing plan when a triggering even occurs

AML employee succession plans should be “living” documents. Keep plans relevant. Follow through on training/professional development needs and set reminders to review/update the plan. Review it annually and when staff changes or other triggers occur. Consider how changes to the risk profile might alter program needs during a triggering event. 

Stay up to date on AML/CFT and fraud trends. Get regular updates created by and for AML professionals.

We can help you navigate changing AML/CFT and fraud regulations. Abrigo's BSA/AML software can help you manage customer or member relationships and stay compliant. Talk to a specialist to learn more.
About the Author

Terri Luttrell, CAMS-Audit, CFCS

Compliance and Engagement Director
Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size.

Full Bio

About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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