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Staffing Assessments: Why Financial Institutions Should Prepare for 2022 Staffing Needs Now

Terri Luttrell, CAMS-Audit
December 17, 2021
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Prepare for Future Staffing Needs Now 

As we transition to 2022, now is the perfect time to analyze current staffing levels at your financial institution. 

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Current Trends
Employee turnover is significantly impacting the financial industry

There is no doubt that the last few years have been a challenge for all, and the financial services industry is no exception. Financial institutions experienced significant changes in 2021 because of the continued pandemic, increased remote work trend, and growing digital usage. Employee turnover is one of the significant impacts seen in the financial industry, as many companies competing for valuable resources offer remote work options that many financial institutions cannot provide. Opportunities for employees in the new remote environment are endless, and according to Forbes Magazineturnover for businesses around the country is at an all-time highMoving into 2022 may be an excellent time to analyze current staffing levels and the associated risks of losing valuable members of your team. 

Adequate staffing is crucial for areas with high regulatory scrutiny, such as the Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) and fraud functions. In their advisory on the importance of a strong culture of compliance (FIN-2014-A007), FinCEN states that one of the keys to a robust BSA/AML program is devoting adequate resources to its compliance function (both human and technological)What better way to strengthen your financial institutions' culture of compliance and build your use case for your senior management than through a comprehensive staffing assessment? Data speaks more than words when budgetary concerns are at stake—every time. 

Be Prepared
Staffing assessments are recommend for your institution

With the passing of the Anti-Money Laundering Act of 2020 (AMLA) as part of the National Defense Authorization Act, FinCEN will be issuing AMLA regulations and guidance throughout 2022 around AMLA requirements and will affect the AML work effort for financial institutions. Each institution will want to ensure you have enough staff to cover the existing workload and any additional duties coming from new guidance.   

Financial institutions have differing AML staffing needs depending on the individual financial institutions' size and risk profile. Small, low-risk institutions may have one compliance officer to run all compliance functions, including BSA. Others may be larger institutions or provide services to higher-risk customers, such as cannabis-related businesses, and will have a much larger BSA staff.  To understand the 2022 needs for your unique AML team, a staffing assessment is recommended to ensure adequate coverage for all duties, so none fall through the crack. Due to missed deadlines, untimely investigation, omitted high-risk reviews, and other significant deficiencies resulting from insufficient human resources, many regulatory penalties have been given. Penalties are expected to increase in this area due to AMLA, including an increased penalty provision for non-compliance and encouragement for whistleblowers to speak up when they see an insufficient AML program. Now is the time to be prepared. 

Learn More
How to perform a staffing assessment

What steps should be taken by financial institutions in performing successful staffing assessments that will ensure you have adequate staff for the current workload and future tasks, some of which may be large projects?  In Abrigo's recent publication of a Guide to a Successful Staffing Assessment, specific steps are addressed in performing a detailed and thorough staffing assessment. The guide includes summarized steps for several important categories, such as conducting a risk assessment, updating policy, procedures, and processes, AML and fraud transaction monitoring, enhanced due diligence reviews of higher-risk customers, and OFAC screening. In addition, the document explains how to track volumes of each category and how to analyze the data to give you the correct number of employees to meet all regulator expectations. 

There are other non-routine aspects of AML and fraud requirements to consider when performing your 2022 staffing assessment. With the release of the FinCEN Priorities, once guidance is released, you will want to update your policies and procedures to address all eight of the priorities and the regulation or guidance requirements that FinCEN will write. Another unique factor to consider is the increase in pandemic-related and cyber fraud, which is expected to continue to escalate into 2022.  

Understanding importance
Don't wait, start planning now

As mentioned, employee turnover nationwide has increased significantly in 2021, and in the critical positions of BSA Officer and AML and fraud investigator roles, this can undoubtedly impact your regulatory risk. BSA is an area that cannot afford time without a filled position, so your staffing assessment should consider that risk. Mitigation of risk in losing these important roles may include comprehensive succession planning and cross-training, as well as an outsourced solution should you find yourself with an immediate need for a position that your credit union is trying to fill.   

Due to the passing of the AMLA, the landscape of the AML and fraud industry in 2022 is expected to undergo its most comprehensive reform since the signing of the USA PATRIOT Act two decades ago. Financial institutions' effort to perform is yet to be determined, but it is essential to be prepared. Remember, regulators don't care how much you have in your budget for staffing. They must be confident that you are sufficiently staffed with the correct number and experience level of staff.  Avoid that criticism by sharing your staffing assessment with your regulators and ensuring your program is sound.  Remember the importance of succession planning for each key team member and consider cultivating and outsourcing relationship now in the event you find yourself with a severe gap in staffing resources. Proper planning is the key, especially with the unknowns coming around the corner. Suppose your financial institution is already tightly staffed, and the thought of finding the time to conduct a comprehensive staffing assessment seems daunting. In that case, an outsourced third party might be your answer. A neutral eye into your AML program is always of great benefit.  

Perform a staffing assessment at your institution today.
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About the Author

Terri Luttrell, CAMS-Audit

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.

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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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