Specific topics for your BSA board training may include the following:
Give a brief history of BSA/AML
The key point to make regarding the history of BSA/AML is to understand is understanding laws and regulations. An excellent place for information is FinCEN History of AML Laws.
Explain key terms
There are a lot of acronyms in BSA that the board may not be familiar with. A reference guide with these acronyms and what they represent can be helpful during training. Some examples include:
- BSA/AML
- OFAC
- FinCEN
- MRB
- MSB
- AMLA
- USA PATRIOT
Explain the five pillars
The board must understand the pillars of BSA: internal controls, a designated BSA Officer, ongoing training, independent testing, and customer due diligence. Explain each pillar and how your financial institution complies.
Set board expectations
The board plays an integral role in creating a culture of compliance. Provide a copy of the FinCEN Advisory during the training.
The Federal Financial Institutions Examination Council (FFIEC) advises that a financial institution could strengthen its BSA/AML culture of compliance by:
- Having leadership that actively supports and understands compliance efforts
- Not allowing compliance to be compromised by revenue interests
- Making efforts to manage and mitigate BSA/AML deficiencies
- Ensuring relevant information from various departments within the organization is shared with BSA/AML staff
- Devoting adequate resources to its compliance function (both human and technological)
- Ensuring that the BSA/AML is effective by conducting independent and competent testing
- Ensuring that leadership and staff understand the purpose of its BSA/AML efforts.
Use OFAC FAQs
Use Treasury OFAC FAQs to gather basic information, then discuss how your bank complies. During the training, discuss the software you have to review potential matches. Review any blocked transactions, any restrictions you have on purchases in foreign countries, or any other risk mitigations you have in place.
Explain activities that require FinCEN filing
Utilize your suspicious activity report (SAR) form for a brief sample of some of the activities that are required to be filed. Discuss thresholds for mandated reporting and how many SARs you filed during the year. Report top filing activities and significant cases (you do not need to disclose the customer or member). For instance, do you have an exceptionally large number of elder abuse cases? If so, what can you do to address those? Utilize FinCEN SAR Stats to determine how your SARs compare to the rest of your geographic footprint.
Address recent fines and enforcement actions
To keep up with constantly changing fines and enforcement actions, Bankers Online can be a great resource. Address some of the recent penalties, especially for any financial institutions that are similar in asset size to your institution, and discuss related issues and consequences.
Emphasize how your AML program benefits the institution
BSA is often perceived as a cost center. Find some actual cases that have benefited from the work of BSA employees at FinCEN Law Enforcement case examples, and civil money penalties can be assessed for insufficient AML programs. Discuss how the community benefits from being instrumental in stopping illicit activity. That is the type of front-page news you want for your institution.
