Introductory BSA/AML Examiner School, Atlanta, CA

Bank of Smithville USA

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Training All employees are required to complete various on-line general BSA/AML training courses assigned through Regulation U. New employees are required to complete assigned BSA training within 30 days of employment. Effective monitoring is currently in place and no current exceptions are noted. As noted in the independent audit, certain specialized training should be developed for several different lines of business. These include The Consumer Loan Specialties Group, Real Estate Specialties Group, Registered Transfer Agent, Trust Department, and Indirect Lending and Leasing. A defined training program should be developed for BSA Unit personnel in order to provide consistency in the various monitoring processes. BSA Officer Marks stated that defined training program development for the BSA unit will be implemented by November 20XX, followed by training for the lines of business by December 31, 20XX. Remote Deposit Capture (RDC) RDC is primarily monitored by the Treasury Management Department (TMD), with the identification of suspicious activity jointly monitored by TMD and the BSA department. A review was performed on approximately 30 RDC customers and did not identify any concerns. The recent internal audit identified one BSA-related issue pertaining to 14 accounts without limits out of approximately 900 RDC customers, which is the responsibility of the TMD.