Most industries now require all staff and management to undergo anti-money laundering training annually. Banking, insurance, law and accounting firms, trust and corporate services providers and others have anti-money laundering regulatory obligations and ongoing AML training requirements. This is because these industries often deal with high value transactions, international banking transactions, and complex corporate structures. All of which can hide currency transfers and criminal proceeds.
We’re hearing from our users more often that regulatory inspections are scrutinizing the AML training provided within an organisation. Ten, maybe fifteen years ago, AML training was a simple tick-the-box exercise, given at staff onboarding and then annually. But those days are long gone. We’ve even heard from our users that some inspectors are interviewing staff separately and asking specific questions about their AML training. This shows us the importance that regulators place on staff training.
In order to help you pass the AML training aspect of your regulatory inspections, we suggest that you shore up your AML training obligations in the following three ways:
Basic Money Laundering Awareness Training
You can often purchase from a third-party a basic “Money Laundering Awareness” training video. If you have a very low budget, you may even be able to find some free videos online. You’ll want to make sure it covers the basics – what money laundering is, the stages of money laundering and the consequences of assisting with money laundering, non-compliance for the staff member and the organisation. You’ll also want this basic training to cover “tipping off”.
Make sure all staff of all levels watch this awareness training. Purchasing the program from a third party means you can focus your resources on other areas of your AML program. During the basic AML awareness training, ensure all staff receive your Anti-Money Laundering Policies and Procedures Manual. Also, make sure that all staff sign-off on their understanding of your AML procedures. This way, you can document their comprehension of the policies. Often, a simple way to do this is through short quizzes covering the most important aspects of your AML procedures. Quiz topics might include who to report suspicious activity to, or understanding the importance of not tipping off.
Industry Specific Training
You should also include money laundering training that is industry specific. Sometimes you can find industry specific training from a professional industry association or a third party. For those in highly regulated industries, the regulator itself may issue training programs. Or, at the very least, they will offer some guidance on what should be in the training. Don’t limit yourself to resources provided by just your regulator either.
You may be able to find some resources for industry specific AML training provided by another regulator in another jurisdiction. Also, keep an eye out for webinars hosted by regulators and agencies that may cover a topic relating to money laundering or a specific regulator (e.g., how to report a suspicious transaction to your local Financial Reporting Unit or what services or products fall under AML regulations).
Role Specific Training
The different roles in an organisation – each having different job responsibilities – means that each staff member will need to assess the threat of money laundering risk differently. For example, the bank teller interacts with the customer differently than a loan officer. The account manager at an insurance company will see account activity of a client not seen by senior management. The professional advisor may not see the value or volume of financial transactions, but will engage with clients and also need to be aware of legal transactions that could facilitate money laundering.
For this reason, role specific money laundering awareness training is very important within your organisation. For many industries such as banking and insurance, you may be able to purchase an off the shelf training program that is fit for purpose. But for some industries – captive insurance, for example – you may need to create your own role specific training program.
AML training can no longer be a “tick-the-box” exercise. It must be strong, in depth, ongoing, and specific to your organisation’s products and services to protect your staff and your organisation. At SILO, we provide our users with a basic money laundering awareness video for their staff to watch. We also have worked with many compliance consultants that are experts in a few industries that can help provide the industry specific and role specific training that is needed to shore up your training program. Contact info@silocompliance.com to learn more.