making sure that the institution develops sound BSA/AML policies, procedures and processes that are approved by the board and implemented by management. The board also has to ensure that the bank maintains a designated BSA officer with qualifications commensurate with the bank’s situation. As noted previously, the BSA officer must report directly to the board and be vested with sufficient authority, time and resources. The board must provide for adequate independent testing of BSA/AML compliance. The board should bear in mind that it has the ultimate responsibility for the institution’s BSA compliance. Training Financial institutions must ensure that appropriate bank personnel are trained in all aspects of the regulatory requirements of the BSA and the bank’s internal BSA compliance and anti-money laundering (AML) policies and procedures. An effective training program includes provisions to ensure that all bank personnel, including senior management, those who have contact with customers (whether in person or by phone), those who see customer transaction activity or those who handle cash in any way, receive appropriate training. Board members also need to receive regular BSA/AML training, though at a much higher level with less detail than institution-line employees. The training needs to be ongoing and incorporate current developments and changes to the BSA, AML laws and 16 NEBRASKA INDEPENDENT BANKER
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