BSA-AML Examiner School Case Study eBook

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BSA/AML Policy and Program

Officer.

4. TRAINING TS&J requires all Bank employees to receive BSA/AML/OFAC training appropriate to their roles and responsibilities at least on an annual basis. The BSA/AML Officer will develop a specialized training program with the goals of: ● Ensuring that Bank employees are knowledgeable regarding the Bank’s obligations and responsibilities under BSA/AML/OFAC law; ● Ensuring that Bank employees are familiar with relevant BSA/AML/OFAC requirements pertaining to their specific job functions; ● Instilling an understanding of the significance of the Bank’s BSA/AML/OFAC efforts and helping develop a strong culture of BSA/AML/OFAC compliance across the Bank; and ● Developing a cadre of Bank employees to detect, escalate, and manage BSA/AML/OFAC compliance-related risks as and when they arise. In keeping with the stated goals above, the AML Officers of Fintech Partners will similarly be required to create and maintain risk-based training that supports their organization’s BSA/AML/OFAC compliance programs. TS&J’s BSA/AML Officer will review Critical Third Party, including Fintech Partner, training programs to ensure that they are comprehensive, tailored appropriately to the relevant audience(s), and delivered in a timely manner. The BSA/AML Officer is responsible for working with the Bank’s CCO to ensure that the BSA/AML/OFAC training program for all employees is incorporated into the annual compliance training plan presented to the Board. The BSA/AML Officer maintains responsibility to ensure BSA/AML/OFAC training is administered and completed. 5. REPORTING To ensure oversight of the BSA/AML/OFAC program, the BSA/AML Officer reports at least quarterly to the Board and management Risk and Compliance Committee on: ● BSA/AML/OFAC compliance trends; ● BSA/AML/OFACmonitoring and testing results; ● Summary statistics on SARs filed per month/quarter; ● Material BSA/AML/OFAC compliance issues and/or escalated issues; ● Status of BSA/AML/OFAC-related corrective actions; and

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