AML 4 MSB 13. Training
From the guidance:
- ensure relevant employees, your agents and their employees are aware of the risks of money laundering and terrorist financing, the relevant legislation, and their obligations under that legislation, know who the nominated officer is and what their responsibilities are, trained in the firms’s procedures and in how to recognise and deal with potential money laundering or terrorist financing transactions or activity
- ensure staff, your agents and their employees are trained at regular intervals
- maintain a written record of what you have done to raise awareness and the training given to your employees, agents and their employees
- ensure that a relevant director or senior manager has overall responsibility for establishing and maintaining effective training arrangements."
Or - in simpler terms.
- Train everybody.
- Refresh everybody’s training regularly
- Maintain training records (including tests of understanding)
- Make sure someone senior is on the hook for ensuring the above is done
From the guidance
"It must include, in relation to money laundering and terrorist financing risks, matters including:
- data protection requirements
- the Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulations 2017; Part 7 of the Proceeds of Crime Act; and sections 18 and 21A of the Terrorism Act.
It should cover, in relation to money laundering and terrorist financing risks, matters including:
- the employee or agent’s duties
- the risks posed to the business
- the business’ policies, controls and procedures
- how to conduct customer due diligence and check customers’ documents
- how to spot and deal with suspicious customers and activity
- document inspection and imposter detection
- how to make internal reports, including disclosures of suspicious activity
- record keeping"
Guidance on training has got better and more prescriptive. Businesses seek clarity - and there’s plenty of it when it comes to training.
All you need to do is whip up a load of uptodate, maintained training materials appropriate to every role in the firm. In case you’d like a hand with that - its kind of right up our alley. Get in touch.