AML/CFT (anti-money laundering and countering financing of terrorism) is an area that is constantly evolving and ongoing training and professional development is a necessity for your staff to keep abreast of developments. Your AML/CFT programme needs to be a living programme that is implemented on a daily basis and is responsive to change. Therefore you need to proactively educate your team on why AML/CFT is important and what the obligations of each person are.
Do staff know their roles?
Make sure that everyone involved is adequately trained
Your team needs to be aware of the risks of ML/TF faced by your business and what their individual contributions should be to averting these risks.
Ongoing training for relevant staff is also a requirement of the regime for your compliance officer, senior managers and any other employee who is engaged in AML/CFT duties. Your procedures, policies and controls for training must be set out in your compliance programme.
You need to consider how to tailor your training programme to cover your obligations under the AML/CFT regime, including:
- relevant AML/CFT law
- how you assess your team’s knowledge, application and retention of AML/CFT training
- how you keep track of your team’s completion dates and completion rates in their AML/CFT training
- how your AML/CFT training is tailored for different employees depending on their roles and the tasks they carry out
Next in The Dirty Money Series: Reviews, audits, records and reporting
Pete’s Real Estate is planning to undertake an independent audit of their company’s AML/CFT risk assessment in November. Is the agency permitted to have an employee conduct the independent audit?
Hint: The person who conducts an independent audit must be independent and not have been involved in the reporting entity’s risk assessment, or the establishment, implementation or maintenance of its AML/CFT programme.