Adopting a training program for AML/CFT –
The Financial Obligation Regulations require Financial Institutions (FIs) and Listed Businesses (LBs) to make arrangements for the training of directors and all members of staff to equip them to perform their obligations under the AML/CFT legal framework and to understand the techniques for identifying any suspicious transactions or other suspicious activities.
FIs and LBs may choose to either develop and administer AML/CFT training in-house or engage competent professionals or businesses to deliver such training.
There are many options available for AML/CFT training in terms of method of delivery, including training manuals, in-person presentations, webinars, online courses, etc. What is paramount is that the participant is able to receive the information being presented, such that he may aptly perform his obligations including the detection of suspicious transactions and activities.
Adapting –
Regardless of the training method chosen, it is important to assess whether the content of training is suitable to the intended receivers. Depending on the audience, the trainer would need to consider whether the information being provided is or should be:
- geared to all staff;
- adapted to nuances of the particular FI or LB compared to the general industry;
- adapted to particular functions and levels within the FI or LB.
The trainer must always keep the objective of the training in mind to ensure it is accomplished.
Test and Follow Up –
A great question to ask yourself after delivery of the AML/CFT Training is; how well did the participants assimilate the information?
Most participants don’t have a natural affection for money laundering regulations, policies and combatting techniques. Many may just see the training as something to get through as quickly as possible so they can get back to ‘their work’, while others may view the training as a break from work. What should be important to the employer is that the information is received and effectively applied in the operations of the company. A great way to assess whether this objective is met is through testing.
Following the delivery of a program of training, tests should be administered in order to assess whether the participants received the information that was disseminated. The assessment should require a passing grade suitable for the level of training that is neither lax nor punitive i.e. requiring neither a maximum of 50% nor 100% correct responses for a pass. A multiple choice answer quiz using similar and opposing response options may be a good avenue to test the participant. This then allows for the application of quite useful analytics to responses.
By analysing quiz responses from our training program we can identify points of interest such as:
- participants who seemingly try to bypass our computer based training and attempt the quiz or copy other participants responses;
- commonly or most missed correct responses which indicate areas for follow up training;
- poor data entry habits which if not necessarily affecting the correct responses, do signal potential problems for client companies regarding collecting, storing and retrieving data; etc.
Having completed the delivery of training and testing whether participants have correctly received the information to a sufficient level, it is important to periodically check the operational output to verify the expected outcome is being achieved. It is good practice to ensure that new employees undergo full AML/CFT training as early as possible, notwithstanding at least within 3 months of employment; and that refresher courses are administered to all staff periodically to mitigate any fall in employee diligence.