For example, at financial institutions that continue to rely on paper-based BSA/AML systems, the need to send BSA staff home likely meant staffers had to drag files home with them, said Terri Luttrell, Compliance & Engagement Director at Abrigo. And since the shelter-at-home orders have lasted so long, financial institutions have perhaps had to rotate sending staff into the office to pull additional files, she added.
Even for BSA/AML staff at banks and credit unions using AML software, shifting work from the customary work environment has meant procedures and processes that have taken years, in some cases, to fine tune have had to be adjusted on the fly. For example, staff working on individual Suspicious Activity Reports will often gather periodically around the conference room table to collaborate – whether it’s once every few days or once a week.
“Without those in-person meetings, it makes the collaboration more difficult,” Luttrell says. “Sometimes you really need to talk it through.” Some staffs are prohibited from using web cameras on their laptops, so it can make face-to-face teamwork – even if it is virtual – impossible. That can contribute to making remote work lonely.
For PPP lenders, many workers might have continued coming into the bank or credit union branch or office, but they were unable to meet face-to-face with co-workers or customers/members due to restrictions on in-branch traffic. They’ve implemented new technologies to adapt, such as online loan applications for their PPP applicants, and video meetings with colleagues.
Other financial institutions that had already digitized lending and credit functions have been able to keep many workers at home. And while a recent survey by The Digital Banking Report of 300 financial service industry executives identified work-from-home challenges initially, they said many of the challenges diminished from April to May, and 81% of those surveyed believed there would be greater remote working opportunities in the future.
Nevertheless, many remote bank or credit union workers have had challenges adjusting to working outside the office. Working while children are in school and require attention, or working simply when other family members are in the house can be difficult, especially if there are numerous interruptions. Luttrell said that in talking with some BSA/AML professionals in recent weeks, some mentioned concerns that the transition to working from home has made it more difficult to meet various FinCEN filing and reporting deadlines. “That’s tough, because they do have hard deadlines,” she noted. “The agencies haven’t cut them any slack.”
While FinCEN’s May 18 notice said it “recognizes the current circumstances may create challenges with respect to certain BSA obligations, including the timing requirements for certain BSA report filings,” it did not relieve financial institutions of their obligations to ensure risk-based compliance with the BSA. Instead, it advised financial institutions to communicate COVID-19-related concerns, such as timely filing, to www.fincen.gov. Other financial institution roles have likely faced similar challenges meeting deadlines in their jobs.
