Safeguarding the integrity and effectiveness of a financial institution’s anti-money laundering (AML) program is paramount to ensuring regulatory compliance and detecting illicit activity. While staffing changes are often foreseeable, unexpected personnel shifts can leave institutions vulnerable and ill-prepared to tackle potential disruptions. Below are six measures institutions can take to protect AML programs against unanticipated risks associated with staffing changes:
6 ways to safeguard your AML program against surprise staffing needs
Assessing and preparing for staffing needs
AML and fraud compliance is an essential obligation for financial institutions. Here are several tips for keeping your AML program running smoothly when staffing needs arise.
Get more tips for managing the AML program from this webinar: "Conquering BSA challenges: Best practices for managing a successful AML program"
Protect against shortages
Is your AML department addressing staffing needs?
Conduct a staffing needs assessment
Staffing should be part of a financial institution’s enterprise-wide risk assessment. By performing a thorough staffing assessment of your AML and fraud teams, you understand the resource needs to meet all quality and regulatory expectations. If a staffing needs assessment uncovers a deficit, it is time to build a business case for senior management to increase your current headcount. If you have a labor shortage when fully staffed, an unexpected departure will only exacerbate existing workload issues and increase regulatory risk.
Create a business continuity plan
A business continuity plan is a document or procedure that details the necessary information an institution or organization needs to continue operating during an unplanned event. This should clearly define the essential functions of the business, identify which process must be sustained, and give explicit details on how to maintain them. The plan should include all types of potential change, including anticipated or planned events, data recovery and backup procedures, strategies for resuming office productivity, communication guidelines, and policies/procedures on unexpected staff changes. The main goal of a business continuity plan is to support critical company activities during a crisis. If a staffing needs assessment shows your employee count is insufficient to support coverage in the event of a staffing change, third-party resources should be identified to fill an unanticipated need.
Keep policies and procedures up to date
Having up-to-date AML policies and procedures can be crucial to the business continuity plan. One of the most critical steps is ensuring that every staff member has an up-to-date procedure guide outlining every daily, weekly, monthly, semi-annual, or annual process. This is a tedious endeavor for every member of staff. However, not ensuring every task is written in full detail could be disastrous for the institution. Procedures should be detailed so that any staff member would be able to completely understand and be able to undertake any task with minimal training. Begin with an outline of each member of your AML team. Spend time with each staff member to be fully able to document each task carefully. This might also be an excellent opportunity to make process improvements or evaluate any function redundancy prior to conducting a staffing needs assessment.
Determine impacts on those affected by the change
Evaluating all team members affected by the unexpected staffing change is critical. Clarify with the staff what has occurred, the anticipated impacts of the change, and the shared vision for moving forward with the remaining team. This can be important while determining actions to replace the staff loss and updating daily routines and activities. Unexpected staff changes can impact the day-to-day processes of the other team members, increasing the workload depending on the member who has departed. Identify the potential increase in time management and any potential deadlines for essential tasks. It is important to note if the staff member was responsible for time-sensitive tasks such as processing BSA or Fraud alerts, cases, SARs, or CTR processing.
Cross-training bank and credit union staff to give them familiarity with one another’s roles is an excellent opportunity for process improvement, employee engagement, and skill development. Cross-training employees gives an added benefit when an unexpected staffing event occurs—it gives you a trained employee who is ready and able to step in as needed with less impact on the institution. Cross-training can also potentially help with employee burnout – doing the same task daily can be tedious for some employees, and learning new skills breaks up the monotony. Cross-training can also help employee growth potential, adding more skills and oversight and perhaps leading to an internal promotion or a training role. Remember that tasks requiring extensive experience or compliance knowledge will need more training and will require quality control processes to ensure proper cross-training.
Communicate and actively involve leadership
Effective communication and support are vital to ensuring that the team can develop a plan to minimize the impact on staff productivity and morale within the remaining group. In an unexpected staffing shortage, leadership must express the situation’s urgency while recognizing the natural response of fear or resistance from the remaining staff. Often, staffing situations mean that remaining employees must give additional time or resources to the institution for a time, so buy-in and open communication are paramount. Implementing a strategy to encourage employee feedback is an excellent way to stay on top of the situation and quickly make process improvements or changes.
The institution’s leadership should implement a support structure for the remaining staff to keep the team informed and minimize impact. After communicating the purpose of the change and developing a clear vision and timeline for staff, support from leadership is an essential part of reassurance to staff.
Lessening the AML/CFT & fraud workload
Preparing for unexpected staffing changes increases the safety and soundness of a financial institution’s AML program. Institutions can proactively implement these six measures to build resilience and adaptability into their AML programs, ensuring smooth operations and minimizing the potential negative impact of sudden vacancies. Remember that sometimes using existing staff to cover unplanned vacancies may not be possible or cost-efficient. Look to your business continuity plan to enlist alternative resources, such as calling on third-party or experienced staff augmentation. Investing in AML software that can lessen the manual workload can help. Embracing these practices will safeguard the institution and foster a more flexible and robust AML program capable of facing any challenges in regulatory compliance. If your institution requires assistance with staffing needs assessments or staff augmentation, contact Abrigo Advisory Services. We have your back.