Who needs AML/CFT training?
AML/CFT training is critical to any Supervised Entity’s compliance with the laws and guidelines. Although the Compliance Officer and/or staff assigned to the entity’s compliance unit are required to perform specific functions, all directors and staff of a Supervised Entity should receive AML/CFT training relevant to their job function. So for instance the courier/messenger is not involved in business transactions but should be aware of the fundamentals of delivery and receipt of correspondence are important in record keeping obligations.
What should be the focus of AML/CFT training
AML/CFT legal obligations can be extensive and requires retention of a lot of information especially as the landscape is constantly evolving. Therefore AML/CFT training must be ongoing and focus on all areas of obligation including:
- Customer Due Diligence procedures
- Enhanced Due Diligence measures
- Identification of high risk customers, transactions and payment methods
- Transaction monitoring and assessment
- Internal and external reporting measures
- Risk assessment
It is not expected that all topics be fully covered in one training. So as not to overwhelm employees, AML/CFT training can be conducted incrementally. It is encouraged that a training plan be developed and some level of assessment to ensure there is understand and change in compliance culture.
Who can provide AML/CFT training?
There are internationally and locally recognized institutions that offer certified AML/CFT programs. Additionally, there are competent professionals that conduct AML/CFT seminars and workshops. If the latter is the option, it is recommended that the training facilitation have extensive knowledge of the AML/CFT legislation and experience in AML/CFT.
The FIU conduct outreach and awareness seminars for our Supervised Entities at least once monthly. These sessions are usually sector specific except where a session is conducted for all sectors.
It should be noted FIU outreach seminars should not be deemed AML/CFT training. The content of our seminars focus on:
- General awareness of legal obligations;
- How to report effectively to the FIU;
- ML/FT/PF trends identified by the FIU.