An Effective AML Training in Four Steps

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 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 received adequate AML training. A company’s weakest link is always one of its employees. Thus, providing sufficient company wide money laundering awareness and compliance training is the best way you can protect your organisation from severe penalties.

While everyone understands that effective anti-money laundering training is essential, not everyone understands how to build an effective training program. But don’t worry; the process is relatively simple. Here are four steps that sum it up:

Use Real World Scenarios

Everyone likes a good crime story. So grab your staff’s attention with some very real, very recent stories that involve money laundering in your industry. Keep it short – no more than two or three minutes. Include ongoing allegations and investigations. And wrap it up by informing staff of recent regulatory penalties imposed on organisations in your industry. 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, to the aftermath of those involved, this information provides great training material.

Provide Updates

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, along with 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. The touch points of AML compliance are very different for each role. Senior management, board members, support staff, account managers – make the training relevant to each role. And don’t forget to provide how the updates on policies and procedures impact each role.

Test Comprehension

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. Additionally, 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.

Conclusion

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 a hugely complex trend. Therefore, it is best to get an expert to provide training on a 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 info@silocompliance.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.

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