Training

All personnel whose duties require knowledge of the BSA must complete training under NCUA regulation § 748.2(c)(4). Ideally, this training is tailored to their job-specific responsibilities, although this is not specified in the regulation. Training topics generally include regulatory requirements and the credit union’s internal BSA policies and procedures.

The frequency of a credit union's BSA training is not specified in regulation. A credit union generally aligns the frequency of training to occur at entry for new personnel and annually for existing personnel. More frequent training may be necessary if the credit union makes significant changes to their BSA program.

Training for officials and senior management focuses on the:

• Importance of BSA regulatory requirements

• Ramifications of noncompliance

• ML/TF risks posed to the credit union

• Credit union’s own policies and procedures

A prudent credit union documents its BSA training program to record what training was provided and to whom and has the documentation available for examiner review. This documentation generally includes, but is not limited to:

• Training and any testing materials

• Dates of training sessions

• Attendance records

Examiners determine whether all personnel whose duties require knowledge of the BSA are included in the training program. Further, the examiner reviews training materials to evaluate whether the BSA training covers requirements, supervisory guidance, and the credit union’s internal BSA/AML policies and procedures.

For more information, see the BSA/AML Training section of the FFIEC BSA/AML Examination Manual.

Last updated on February 02, 2023