Staffing Assessments

Model Validations

Model Validations

It is critical that management periodically assess the adequacy of its resources to assure it is commensurate with the risk.

• Increased examiner findings do not mean that all institutions must boost the number of staff and increase staff salaries. However, it is crucial for an institution to have adequate staffing that corresponds to the risk profile of its customer base and activity.
• Many recent cases have demonstrated that a financial institution must thoughtfully evaluate the adequacy of resources available to the AML department. Where requests are made for increases in AML staffing, salary, or technology, officers and directors should ensure that such requests are properly evaluated and appropriately documented.
• Examiners will be considering whether or not the institution is sufficiently staffed for their overall risk level, size, and fraud/compliance needs. In addition, they will be trying to ensure that staff is given adequate time to execute all duties without conflict of interest.

Arc-Serv’s ultimate goal is to help your institution understand your operational capabilities to achieve a truly sustainable risk program through a robust staffing assessment.

The aim of a strong program efficiency analysis will be to ensure that the institution has adequate staffing, experience, and resources to successfully and efficiently complete all the required tasks to support the institution’s department objectives.

A staffing assessment should:

• Be forward-looking to ensure that the institution has sufficient staffing to handle any anticipated growth and expansion plans.
• Assist the institution in determining its current task transaction volume averages, processes, and procedures and if it is staffed adequately to complete any existing backlogs while still completing all the other required functions and tasks.
• Adequately detail the staffing needs in the current environment at the institution in order to complete to meet all required tasks and allow the department full coverage during vacations or increased/growing demands.
• Include the experience and knowledge of current staff to establish if there are any knowledge gaps or training needs to ensure the institution has an appropriate level of experience to maintain an adequate BSA/AML program.
• Evaluate the effectiveness of the department, including best practice recommendations.