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AML/CFT Advisory Services AML Training BSA Rules and Regulation Financial Crime

6 Steps to build an AML/CFT staffing plan for unexpected changes

Terri Luttrell, CAMS-Audit, CFCS
November 26, 2024
Read Time: 0 min
two men and woman around a desk

How staffing assessments and preparation can help handle surprises 

Unexpected AML/CFT staffing turnover can be stressful. Prepare for employee changes with a staffing plan to limit pressure and compliance risk.

Key topics covered in this post: 

Retirements, leave of absences, and exits can upend AML staffing

Employee turnover remains a significant concern for the financial services sector and for AML teams in particular, with many companies offering remote work options that increase competition for staff.

Financial institutions must prepare for unexpected changes in their AML staffing, whether related to the AML/CFT Officer retiring or a key staff member going out on leave, departing for a new opportunity, or going on vacation.

Planning now will mitigate the compliance risk from staff turnover and reduce stress for you and your AML/CFT program during times of change.

 

Are your AML operations short-handed? Let Abrigo’s AML/CFT consultants help.

BSA/AML advisors

The value of BSA staffing plans

Having a thorough AML/CFT staffing assessment will help you know where to start and how much of a burden you will have if an unexpected change occurs on your team. It helps banks, credit unions, and non-bank financial institutions avoid or at least plan for financial impacts tied to sudden staffing shifts.

Here are six steps that will help ensure your anti-money laundering/countering the financing of terrorism program is able to continue meeting obligations regardless of turnover.  

 Identify crucial AML/CFT staff positions and processes

  • What tasks are critical to daily operations? 
  • What tasks are required by regulations? 
  • Who performs those tasks? 
  • How often are they performed? 
  • Are there multiple people assigned to projects or tasks to share responsibilities?

Assess key talent for AML/CFT needs

  • Review the current  team roster and their skills and qualifications. 
  • Review the current workloads of relevant employees. 
  • Ask employees directly how they feel about their job skills. Find cross-training opportunities for team growth. 
  • Identify all potential backups for each critical task. 

Incorporate professional development

  • Interview each employee for their professional growth desires. . 
  • Gauge interest in and willingness to take on other tasks or roles. 
  • Identify who is ready now to add tasks or roles vs. who needs additional training. 
  • Document who can do what if roles need to be adjusted unexpectedly. 
  • Cross-train and develop staff. 

Anticipate possible triggers of AML/CFT staff changes (institution-specific)

  • Promotions.
  • Terminations and resignations.
  • Leaves of absence, vacations, and sabbaticals.
  • Regulatory changes affecting your anti-money laundering program.
  • Major institutional realignments that could affect available backup resources.

Use results from above to document and approve an  AML/CFT succession plan

  • Scout key AML/CFT positions and talent.
  • Watch for triggering events.
  • Build out and document plans to remain BSA-compliant.
  • Include HR in adding steps for replacing staff.
  • Submit plans to AML/CFT program executive management for approval.
  • Share with the board. It must appoint any interim or new officer when an AML/CFT Officer leaves or requires an extended absence.
  • Amend as needed.

Activate the staffing plan when a triggering event occurs

AML employee succession plans should be “living” documents. Having a current staffing assessment and understanding the strengths of your team are essential.

Keep plans relevant. Follow through on training and professional development needs and set reminders to review and update the plan. Review it annually and when staff changes or other triggers occur.

Finally, consider how changes to the risk profile might alter program needs during a triggering event.

Unexpected staff changes can be stressful. Having a plan for employee changes and keeping it updated and relevant will help limit the pressure and compliance risk. If you need help with a staffing assessment, a staffing plan, or staffing in general, Abrigo’s BSA/AML consultants can help. They can also help bridge AML staffing gaps.

Key Takeaways

Employee turnover is a major concern for financial institutions and for AML teams in particular.

AML/CFT staffing plans help mitigate compliance risk and reduce stress when staff changes leave gaps.

Use a staffing assessment and these six steps to ensure your AML program will be ready to meet obligations.

You might also like this AML staffing calculator.

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About the Author

Terri Luttrell, CAMS-Audit, CFCS

Compliance and Engagement Director
Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size.

Full Bio

About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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