Can you believe it’s already September? Over half the year has passed, and most likely, a lot of that time has been spent working remotely and in virtual meetings. Given all of the time and effort dedicated to managing through COVID-19 and this “new normal”, we want to remind you about your annual BSA Board training!
On April 3, 2020, the Financial Crimes Enforcement Network (FinCEN) provided further information in response to the Coronavirus Disease 2019 (COVID-19) pandemic. While this release acknowledged the potential for CTR reporting delays (and delayed implementing the new CTR filing requirements for DBAs), there wasn’t grace granted for anything else.
While the regulation doesn’t technically require “annual” Board BSA training per se, it has become an industry expectation. The Board should be updated, at least annually, on BSA even if there are no changes. We believe doing so is a good reminder to the Board of how important BSA is. It also keeps BSA in the forefront, since the Board is ultimately responsible for BSA compliance.
Given the environment we’re in, with revisions to the BSA/AML Exam Manual, COVID-19 pandemic-related scams, and the unique and often remote operating environment, updating the Board to ensure their BSA knowledge remains sharp is critical. Hint hint…those three things might be great additions to this year’s training, in addition to the general BSA requirements.
Below are questions we find engaged Boards ask their BSA Officers, and are great to keep in mind when developing your Board training to ensure you’re providing them with the things they need to know to sufficiently execute their duties. The answers to some of these may be found within your independent test, but there may have been updates to your program since then as well:
Are we doing the right things, and are we doing them well? How do we compare to others?
Know what enforcement actions and penalties are being imposed.
Are we sufficient, competent and effective?
Is your program effective? Is suspicious activity being identified and referred /reported?
Are our program components properly positioned?
Are you devoting resources and staffing to those areas of greatest concern/risk?
Are we outsourcing and in-sourcing the right processes in line with our competencies and economies? Are we properly managed and accountable in all cases?
If conducting an internal independent audit, should it be outsourced? Should third-party vendors be used for OFAC, 314a, identity verification, etc.?
Top-down and bottom-up – is our program working as intended?
Is enough information being reported UP to the Board/Management so they can provide appropriate direction DOWN in the form of resources, authority, etc.?
Now is a great time to start thinking about your annual BSA Board training, if you haven’t already done so. BSA is not something you want to let fall on the back burner during these unprecedented times. If you need help or want more training, we have a wide variety of BSA-related webinars available On Demand. We also have a webinar devoted specifically to annual BSA training for your Board & Management coming up on December 10, 2020.
NEED FREE BSA or AML Tools? Check them out here – https://store.bankerscompliance.com/link/BSAFreeTools
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them.
Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).