Objectives of the Anti-Money Laundering Certification Program:
- To achieve recognition of the skill level required for the examination of adherence to Bank Secrecy Act/Anti-Money Laundering (BSA/AML) laws and regulations applicable to regulated financial institutions and Money Service Businesses.
- To promote continuing education in the BSA/AML area of examination.
- To emphasize the need for professionalism and continuing advancement of BSA/AML examination professionals given the specialized skills and knowledge necessary to adequately supervise this area.
- To enhance and maintain the quality of job performance and skill level of BSA/AML regulators.
Candidates for Certified Bank Secrecy Act Specialist designation must provide evidence of all of the following:
- Serve as the lead BSA/AML examiner during a minimum of 12 months' of on the job experience in the BSA/AML area (or equivalent*) and five exams with the BSA portion included in the final report and accepted by all pertinent supervisory agencies.
* The equivalent experience should include review for BSA/AML compliance in a financial institution or money service business with communication of findings to the appropriate parties. Details of equivalent experience must be submitted with the application.
- Satisfactory completion of at least 28 hours of education in the following course offerings or their equivalent:
- CSBS BSA/AML Examiner School
- FFIEC Money Laundering Workshop
- FinCEN BSA Training (in development)
- FRB or FDIC BSA Workshop
- FRB BSA/AML Hands-on Lab
- Attestation of successful job performance and mastery of appropriate job-related skills by a superior within the candidate's organization. All attestations shall be considered final once signed. A defined response form that outlines the necessary and appropriate skills will support attestation as to a candidate’s skill. A high degree of reliance is placed on the attestation forms provided by the applicant’s supervisor when granting certification. For that reason, the individual signing the form should be familiar with the applicant’s experience, performance, and skills abilities and confident that the applicants meets all the requirements as noted on the form.
The attestation form addresses the following categories:
TECHNICAL - Provides effective leadership and organization to the examination process:
- Demonstrates effective supervisory skills to plan, organize and delegate examination/ inspection functions
- Effectively supervises personnel to ensure adherence to examination policies and procedures
- Actively participates in all phases of on-the-job-training of other examiners
- Supervises, organizes, and effectively documents workpapers according to prescribed procedures
CONCEPTUAL - Provides effective and accurate evaluation of the overall activities of financial institutions/money service businesses relating to BSA/AML:
- Effectively demonstrates knowledge of the Bank Secrecy Act, Homeland Security Act and other AML policies, procedures, laws, rules and regulations
- Effectively follows established examination procedures to collect and analyze data
- Preparation of written comments is factually and technically correct
- Workpapers support report of examination with detailed information and provide a clear audit trail
- Effectively reviews the BSA/AML portion in the reports of examination for accuracy, content, conclusions, and proper grammar
LEGAL/COMPLIANCE - Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations related to anti-money laundering and the Bank Secrecy Act.
HUMAN RELATIONS - Provides effective oral and written communications:
- Effectively communicates assignments to other examination personnel
- Effectively communicates with financial institution/money service business management/personnel to obtain information
- Presents logical supporting arguments in response to any management objections and moderates own conclusions if presented with sufficiently supported data by management
- All meetings are performed in an organized and professional manner
- Recommendations and ratings demonstrate a thorough and successful understanding of regulations, statutes, and directives as applicable to the entity under examination/inspection
Anti-Money Laundering Specialist Recertification
Every three years, participants will be required to provide evidence of the successful completion of a minimum of 40 continuing education hours (CEH); at least seven CEHs must be completed each year. Examples of qualifying programs and activities are listed below. Other programs and activities submitted will be considered on a case-by-case basis.
The following courses would qualify as continuing education:
- CSBS BSA Specialist Seminar
- Applicable portions of Annual Conferences or other seminars of:
- Federal Agencies