An Effective AML Training in Four Steps
September 18, 2020
Anti-money laundering training (AML) is a critical part of any business that operates in the international financial sectors. Any allegations of money laundering involving your organisation can cause serious reputational damage, incur severe penalties, and significantly damage one’s career. As the AML Compliance Officer, Money Laundering Reporting Officer or Risk Manager of your company it is important that you can demonstrate you have provided adequate AML training. A company’s weakest link is always one of the employees – so company wide money laundering awareness and compliance training is very important because it can help protect you and your organisation from severe penalties if you can prove you provided sufficient and relevant AML training.
While everyone understands that effective anti-money laundering training is essential, not everyone understands how to build an effective training program. The process is relatively simple and can be summed up in four steps:
Use Real World Scenarios
Everyone likes a good crime story – so grab your staff’s attention with some very real and recent stories about what has happened in your industry that involves money laundering. Keep it short – no more than two or three minutes. Include allegations and investigations that may be going on, but wrap it up by informing staff of recent regulatory penalties that were imposed on organisations in your industry or by your regulator. This will help your staff connect what they read in headlines with the very real cost of non-compliance for them and your company.
So keep a log of headlines and cases that you come across in the news – from the initial sting reported to the result of the court case and what happens to the professional’s careers that were involved.
Money laundering trends and tactics change constantly. Include a few minutes in your training to discuss those new trends and industries that are trending risks.
But also update the technical stuff – what regulations changed, what aspects of internal policies and procedures changed. As the money laundering trends change, the anti-money laundering regulations and expectations by regulators are also always changing. Your annual training program needs to be updated to inform your colleagues of those regulatory changes and their impact on internal policies and procedures.
Make AML Training Relevant
One of the biggest problems in corporate training is helping trainees connect what they learned to their jobs. It’s easy to spend hours talking about money laundering trends and investigations – but you’ll be wasting your colleagues’ valuable (and often revenue generating) time if they can’t walk away knowing how to apply that awareness to protecting your organisation – which is the primary goal of AML training.
Address this by understanding the roles and responsibilities of each attendee. If you’re from a larger organisation, you may need to split training sessions. Senior management, board members, support staff, account managers – make the training relevant to each role because the touch points of AML compliance are very different for each role. And don’t forget to provide how the updates on policies and procedures impact each role.
It’s common practice to provide a report to AML regulators and AML auditors that records who took training when. However, some regulators and auditors are starting to test those records by interviewing random staff about their training. Be prepared for this to occur during a regulatory visit.
You can also ensure all staff take a quiz or test to document their comprehension after training sessions. This is also important if you have a colleague that gets involved in some money laundering scheme and tries to say they didn’t have enough training to be aware that they were involved. If they passed a well written test, then you’ve done your job in protecting your organisation. Don’t forget to include contractors and part-time employees in your training logs and also to make sure you get any long-leave returning workers (e.g., those that had been on sabbatical or maternity and paternity leave) caught up on AML training.
You can create your own anti-money laundering training course if you have the time, or, depending on your budget, you can start with existing programs or even hire an AML compliance consultant to provide training. A hybrid approach is also acceptable. You can provide the basic money laundering awareness training and train on new policies and procedures while outsourcing any knowledge or experience gaps with one-off training provided by consultant. For example, trade-based money laundering is hugely complex trend – best to get an expert to provide training on that topic if you’re not familiar with it.
At SILO Compliance, we understand how important (and time consuming) AML compliance is to protect your business. We encourage our users to utilize the training section of their SILO Complaince System to create various training modules in order to document and demonstrate to AML auditors and regulators that staff AML awareness training has been implemented and all staff comprehended their training. This is one of the critical aspects of protecting your business.
Contact us at email@example.com to learn more about SILO Compliance System and the training section in SILO to see how it can help you meet your AML compliance needs.