The report states: “AML
training for all staff, including the AML division, consisted of short online
videos with no assessment”.
Senior management is responsible for
approving the AML training programme and ensuring its sufficiency, correctness
and completeness. The success of the firm’s AML compliance programme is
directly attributable to the effectiveness of its training programme. Senior
management and AML division employees should be the firm’s most educated in
terms of AML measures. Educating the AML division and other employees through
only short online videos puts the firm at risk of having inadequate and
uninformed AML leaders who are in no position to properly educate staff, and
all employees at risk of not understanding how money laundering and AML
measures relate to the firm. The firm is also at risk of non-compliance with
AML Acts and Regulations.
Training should be specific to the
firm and tailored to policies, procedures and controls that relate to
employees’ day-to-day job responsibilities. Case studies and real-life examples
should be used to demonstrate the reality of money laundering.
The training programme should ensure
that employees are aware of relevant AML Acts and Regulations and their
obligations in relation to them. Employees should be required to read the
firm’s Manual and understand their responsibilities in relation to it.
Lack of assessment puts senior
management at risk of being unable to gauge the level of knowledge and
understanding of the AML division and other employees, or the effectiveness of
the training programme.
Training must be ongoing, take place
at regular intervals throughout the year and include periodic assessments. AML
division employees should be required to take advanced classes in AML measures
and to work towards related qualifications.
To ensure the effectiveness of its
training programme and compliance with Acts and Regulations, the firm must keep
detailed records of all training sessions including dates of sessions,
attendance, subjects covered, assessments given and assessment results.