Your guide to building a stress-free staff AML training plan 🍎
Training your staff is one of the most important ways to stress the importance of AML/CFT matters and to mitigate the money laundering risks that your organisation may face.
Having a comprehensive AML training plan is a must, not only for risk mitigation and operational efficiency purposes, but also to prevent your organisation from falling foul of the law. Failure to have proper AML training in place can result in formal warnings and enforcement action from your AML/CFT Supervisor. Ouch.
But here’s the good news: we’ve done most of the heavy lifting for you, and broken down the important things to consider when building your own AML training plan.
Here’s what we’ll be covering:
- What a training plan needs to cover
- Who needs training
- What to train on
- What to put into your AML/CFT Programme
- Methods of training
- Assessment and record keeping
What a training plan needs to cover
At a broad level, your AML/CFT staff training plan needs to cover:
- The purpose of the training,
- Who requires training,
- How your training will be carried out, and
- How training records will be maintained.
Your training plan should be documented in writing and stored somewhere that it can be easily retrieved, should it be needed internally or for an external AML audit.
Who needs training?
So who needs training? You will need to think about the different types of employees in your organisation that need to have awareness of AML/CFT matters. At a minimum, this should include:
- The AML/CFT Compliance Officer,
- your senior managers, and
- any other staff who have AML/CFT-related duties.
Staff with AML/CFT-related duties can capture a wide range of different employee groups within your organisation. For example this might include, compliance staff who carry out AML/CFT related processes; administration staff who are responsible for opening new accounts and onboarding new clients; finance staff who deal with client accounts and processing transactions; as well as professional and/or other client-facing staff who regularly interact with customers.
What to train on?
Important training topics for staff to know about include:
- Your internal AML/CFT procedures
- The sorts of things staff should look out for
- Who to alert when something doesn’t look right
- How to document AML/CFT records
It’s also important to consider how you will tailor training for different roles. Role-based training is often most appropriate, allowing training topics and frequency to be adjusted based on the AML/CFT responsibilities involved.
AML/CFT Compliance Officers
Compliance Officers need to have a high-level of understanding of both the AML/CFT regulatory requirements and the organisation’s specific AML/CFT risks. More advanced and regular training to stay ahead of compliance requirements and emerging risks is important.
Senior Managers/Board of Directors
Decision makers and/or owners of an organisation should have training about the importance of AML/CFT regulatory requirements, consequences of non-compliance and personal liability. This ensures strong AML/CFT oversight and that a culture of compliance is embedded within the organisation.
Other Staff
Staff need to have a solid understanding of why AML/CFT matters are important, what they need to do to comply with policies and how to remain vigilant against money laundering. A general course will often be able to address most of these issues with some additional training on organisation-specific processes.
What to include in your AML/CFT Programme?
As well as having your written staff AML training plan, it’s important to document the key aspects of the training plan within your organisation’s overall AML/CFT Programme.
Your AML/CFT Programme should have a section on training that sets out your organisation’s approach and details:
- Which roles require training
- How the training will be tailored
- How often training will be delivered
- What methods of training will be accepted
- How training will be assessed and recorded
Methods of training
Training can be delivered in a variety of ways. For example, it can be:
- Meetings or informal group discussions
- Structured formal sessions about AML/CFT topics
- Attendance at presentations or conferences
- Reading AML/CFT related publications
Online training e-learning modules are a popular method of training because they enable flexibility in when and where training can be delivered. They also enable clear record-keeping and follow-up assessment to ensure that training is understood.
Assessment and recording keeping
Keeping a record of your staff AML training is important. This will be requested during an external AML audit and should be regularly updated. Your training register should include records of:
- Who completed training
- Description of the training/activity
- What topics it covered
- How long the training was
- The trainer’s details
Key things to remember
Phew. Now you’re well on your way to building a robust staff AML training plan. As you’re putting pen to paper, remember these important things:
- Staff training is essential for all AML/CFT reporting entities
- Training must be ongoing and regular
- It must be regularly reviewed and should suit the size and risks of your organisation
- Training should be tailored for different roles within the organisation
- It should be clearly documented with sufficient training records kept
Still have questions?
We love to answer your questions. Contact us with any AML training-related questions and one of our team will be in touch ASAP.
You can also reach out to the AML/CFT supervisor responsible for regulating your sector at the emails below:
- Reserve Bank of New Zealand (amlcft@rbnz.govt.nz)
- Financial Markets Authority (aml@fma.govt.nz)
- Department of Internal Affairs (amlcft@dia.govt.nz)
Thanks for reading! See you next time 😀
Material in this article is licensed under the Creative Commons Attribution 4.0 License. It is attributed to the Financial Markets Authority.