AML Training Program Requirements

C

Sure, I'd be happy to provide a detailed explanation.

An AML training program is an important component of an effective anti-money laundering (AML) compliance program for financial institutions. Such a training program should aim to educate all employees on the requirements of the Bank Secrecy Act (BSA) and other applicable AML laws and regulations, as well as the institution's own AML policies and procedures.

Of the four options provided, the most appropriate answer is C. New staff should receive training during employee orientation or shortly thereafter on bank procedures. This is because it is important for new staff members to receive AML training as soon as possible after joining the financial institution. This will ensure that they are aware of the institution's AML policies and procedures from the outset and can integrate these into their daily work practices.

Option A is incorrect because it suggests that training on the identification of suspicious or unusual activity should only occur after the new teller has been with the institution for one year. This is not optimal as it may allow suspicious or unusual activity to go unnoticed during the initial year of employment.

Option B is also incorrect because it suggests that new lending staff should only receive annual training on the preparation of currency transaction reporting. This is not sufficient because AML training should cover a broader range of topics beyond just currency transaction reporting.

Option D is also incorrect because it suggests that only operational staff should receive training on currency transaction reporting exemptions. A comprehensive AML training program should ensure that all employees are aware of relevant AML requirements, including those related to currency transaction reporting.

In summary, the most appropriate requirement for an AML training program is that new staff members should receive training during employee orientation or shortly thereafter on bank procedures.