Which of the following is not explicitly listed as part of a comprehensive BSA training program?

• A. Documentation of attendance records and training materials
• B. Penalties for noncompliance
• C. Company policies, procedures, and processes
• D. Scheduled external audits of the AML program

Answer: (D)

The main idea here is what is typically included in a comprehensive BSA training program. Training programs focus on what employees need to know and how to apply it, and they also document that training occurred. That’s why documenting attendance and the training materials used is a standard part of the program. The training should reflect the company’s policies, procedures, and processes so staff understand the rules and how to act in real situations. It may also cover penalties for noncompliance to reinforce the seriousness of these requirements.

Scheduled external audits of the AML program, however, are governance and oversight activities. They assess and verify the program’s effectiveness, but they aren’t a component of the training content that employees go through. So, those audits aren’t typically listed as part of the training program itself.