Three Ways to Shore up your Anti-Money Laundering Training
September 18, 2020
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 are often dealing with high value transactions, international banking transactions and complex corporate structures that can be used to hide currency transfers that hide 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 fairly easy tick-the-box exercise given at staff onboarding and then once a year. But those days are now 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 indicates the importance that regulators are placing 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 ML awareness training, ensure all staff receive your Anti-Money Laundering Policies and Procedures Manual. Also, ensure all staff sign-off on their understanding of your AML procedures and that you can document their comprehension of the policies. Often this is done by giving a short quiz covering the most important aspects of your AML procedures – such as who one would report suspicious activity 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. If you’re in a highly regulated industry, the regulator itself may issue training programs or, at the very least, some guidance on what training should consist of. 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 suspiciuos 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 numerous 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 firstname.lastname@example.org to learn more.