The institution must employ an automated system for AML detection— that will enable it to detect most instances of money laundering. The BSA Officer will print and maintain reports produced by the system to substantiate his opinion that specific activity is, or is not, suspicious.
In addition to using the system, all employees will receive training once a year on how to identify money laundering operations. (New employees that have direct contact with customers will receive initial training within the first four weeks of employment.) As a part of the training, each Teller and New Accounts Representative will be given a laminated card that identifies ways to detect and prevent money laundering. Replacement cards will be available from the BSA Officer.