One of the crucial components of managing financial crime risk is ensuring that employees are adequately trained in anti-money laundering (AML). Some countries make regulations for requirements on training. For example, in the UK the Money Laundering, Terrorist Financing, and Transfer of Funds Regulation 2017 have clear requirements on training, and the financial conduct authority (FCA).
The Essentials
No matter in what jurisdiction a business operates, regulation should be the first point of call when determining AML training obligations. Money Laundering, Terrorist Financing, and Transfer of Funds Regulation 2017 outlines two key requirements for employees training.
Employees should be aware of the laws to money laundering and terrorist financing. By any means, this awareness level training could be carried out. Most popular is mandatory online learning, by which knowledge can be delivered to a large and disparate group of employees.
It requires agents and employees are regularly given training on how to recognize and deal with transactions and other activities which may be related to money laundering or terrorist financing. This is where it gets interesting, and there is a broad range of training solutions that can be acquired or
designed to meet those needs.
Anti-Money Laundering (AML) training program can consider the following questions:
1. What are the business training needs?
While determining the needs, consider the following:
- Awareness of the risks faced by the business
- Current knowledge of agents and employees
- What can be done differently by agents and employees ?
Employees and relationship managers in a payment processing team are at the fore forefront of identifying suspicious activity. Businesses also need to consider the impact the roles have on the AML framework when determining the role & activities that are high risk. Because roles are different from being customer-oriented, hence the risk they deal with will be different. If an employee needs to assess risk when designing products, then he should have training that enables him to appreciate AML risks and control framework. Role-based training is an ideal solution for this, as it can be tailored to the specific activities unique to that role and risk faced.
Identifying whether training is the right solution
Training is not the only solution for all problems. There can be others like systemic issues that training struggles to cover. Training can not solve the problems that arise from being under-resourced or technological issues. It does not matter how well employees are trained, if they have insufficient resources, they will not be able to carry out their functions appropriately. With all being said, we can not deny that training is a key component of the risk management framework.