Programmes are required to set out how a
business will provide adequate and effective training to its senior managers,
AML CFT compliance officer and any employee whose role exposes them to the risk
of facilitating money laundering or terrorism financing.
Employees who are exposed to ML TF risk include those who have direct contact with customers, open customer accounts, handle cash, process
transactions or process customer information.
Additionally employees in compliance, accounting and internal
audit departments should attend AML CFT training. These groups of
employees will be a firm's strongest defence against money laundering or its
weakest link.
Attendance Records - Businesses should ensure they maintain
attendance records so that they can evidence employees have completed the
training. Records should also detail the type of training
received.
Training Plan - In considering a training plan, businesses
need to keep in mind the objectives they are trying to achieve, which is to
create an environment effective in preventing ML TF and which thereby helps
protect individuals and the business. This may mean different training packages
for different departments. To test an individual's knowledge against the training received, it is recommended that training provide for some form of evaluation to
confirm each participant has understood the training. Retaining records of training material will
allow the quality of the training to be assessed during independent audit
reviews.
For new employees, businesses need to make arrangements to ensure they
are trained as soon as possible.
A basic training programme should include –
Background of money
laundering and terrorism financing, including the differences between the
two;
Customer due diligence
requirements (identification and verification);
Obligation to conduct
ongoing due diligence;
Obligation to report
suspicious transactions;
Suspicious matter red
flags and case studies;
Offence of Tipping
Off;
Consequences
of non-compliance with the AML CFT Act and Regulations.
