Staffing assessments: Why financial institutions should prepare for 2022 staffing needs 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.