Training – More than just a good idea
It’s hard to complete any job well without some training and many jobs require significant training to be completed at all. But in many areas of life, people jump right in without any training thinking they’ll simply learn “on the job”.
That may be fine for some things… but more is expected of financial instiutions. And, as you know, a money services business is a “financial institution” under the law known as the Bank Secrecy Act.
MSBs are required to have an ongoing training program for their employees – in fact, it’s one of the “4 Pillars” of an effective compliance program. The training needs to be
- appropriate for the risk level of the MSB,
- reach all employees with BSA knowledge specific to their position and responsibility, and
- be performed at least once each year.
Employees involved in financial service transactions should also receive training on their Bank Secrecy Act responsibilities prior to performing financial transactions without direct supervision. If you have a “new employee checklist” that you use to check off important steps to acclimating new staff to your business – add your BSA compliance program.
Additionally, the training needs to be documented. During your Independent Review of compliance (and during any FinCEN, IRS, state regulatory agency, or bank review) an MSB must be able to show that its employees received appropriate training.
Appropriate documentation of training would generally include:
- Nature of training provided (individual, video, computer based, etc.)
- Name of trainer, company name, brief bio (if applicable)
- Duration of training
- Persons in attendance
- Copy of materials maintained for files
As you have staff meetings throughout the year, be sure to speak about and reinforce your compliance expectations periodically and include that along with your training documentation.
With proper training, your staff will meet your compliance expectations. They will also help to protect your business from potential civil and criminal penalties and from potential operating losses.