BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 3.1: BSA Compliance Program General Requirements (cont.)

Trainin

Yes No

N/A

Are all of the following elements adequately addressed in the institution's BSA/AML training program and materials: • The importance the board of directors and senior management place on ongoing education, training, and compliance?

Y

• Employee accountability for ensuring BSA compliance?

Y

• Comprehensiveness of training, considering specific risks of individual business lines? • Training of personnel from all applicable areas of the bank? (As part of this element, determine whether the bank conducts adequate training for any agents who are responsible for conducting CIP or other BSA-related functions on behalf of the bank.) • Coverage of bank policies, procedures, processes, and new rules and regulations? • Coverage of different forms of money laundering and terrorist financing as it relates to identification and examples of suspicious activity? Frequency of training?

Y

Y

•

y

y

Y

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