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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 that 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.