On-going employee training

Can include formal training, as well as emails, newsletters and team meetings with AML content. Most areas of the business should have AML training, and it should include most staff. The training should only cover items relevant for those staff, and include real life examples. Attendance or performance should be tracked, with failure to attend or achieve a minimum score addressed through disciplinary procedures.

  • Key training by staff type:

    • Customer-facing: this is the front line of defence, they need a deep practical understanding of AML. Cash handing staff need to know how to identify suspicious cash transactions, credit officers need an understanding of how credit can be used for AML purposes.

    • Back office: cash vault, wire transfers, trade finance all need specialist training. Many back office roles may only require general training.

    • Audit and compliance: training on changes in regulation and law, money laundering methods and enforcement.

    • AML Compliance: training to stay on top of changes e.g. attending conferences .

    • Senior managers & board of directors: strong board support is needed and AML should be regularly communicated, they need understanding in line with their responsibility.

  • Training topics:

    • General information/background, importance of AML

    • Legal framework & applicability to organisation and staff

    • Penalties – disciplinary action, fines and jail

    • How to deal with suspicions

    • Internal policies & procedures

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