Out-source your training
Chapter 7 of the JMLSG Guidance is a good place to start when considering how you will organise effective Anti-Money Laundering training within your firm to comply with the new 2017 Regulations. Chapter 7 sets out with admirable clarity what the Regulations require of firms and includes references to the underlying law and FCA Handbook.
If you are concerned that your firm might be vulnerable to other business risks such as fraudsters, cyber crime and other regulations it would make sense to roll these into your AML training programme.
It is also worth noting that staff members who do fall foul of the Regulations have a defence that the firm did not provide adequate and regular training to equip them with the “skills, knowledge and expertise … to carry out their functions effectively”.
Under the new 2017 Anti-Money Laundering Regulations an AML training programme that consisted of having staff complete an online AML Quiz once a year would guarantee the staff member being exonerated and the MLRO, AML Board Member, the Board and the Firm being hammered.
What we offer
As part of our standard AML Compliance Solution package we keep startup costs low by training the firm’s Compliance Team. They then train the rest of the staff.
We provide training materials within the Help system and a suggested framework but it is down to the Compliance Team to train the rest of the staff.
An alternative that is available to all firms whether or not they use our software is that we will design and run your AML Training Programme. Throughout the process we will liaise and work closely with your MLRO and Compliance Team.
Designing and running your AML Training Programme
Content: Our starting point in designing an AML Training Programme for you will be your Firm’s Risk Assessment. If this is in need of updating we can help with this.
Roles: Each member of staff who is a “relevant employee or agent” in terms of the Regulations will be allocated a role. We will agree a Personal Training Plan (“PTP”) with your MLRO for each of these roles. Working with your Compliance Team we will tailor the standard PTP to each member of staff and agree it with them.
The categories of roles we have found can be adapted to work for most professional firms are:
- Accounts Staff
- Fee Earner/Case Handler
- Compliance Team
- MLRO, Deputy MLRO and SMF Manager
- AML Board Member
The content and scope of the PTP for each role will be based on a suitably tailored version of what is covered in the AML Training Academy Certificate for each of these roles.
We can arrange for new members of staff to complete role appropriate training as part of their induction and do the same for existing members of staff who change roles within the firm.
Delivery: We will agree with you who is to be trained, within what timescale and how that training is to be delivered.
The vast majority of training can be distance learning via private study, interactive webinars, videos, solving scenarios in the Training Area, Quizzes etc, but face to face workshops are always good, and probably essential for some roles.
The agreed dates will be confirmed with each member of staff and added to their PTP.
Record Keeping: We will maintain a record of who attended training and how useful they found each session. If gaps in skills or knowledge are identified further training will be arranged.
We will provide information for inclusion in the MLRO’s periodic report to senior management on:
- who has attended,
- when they attended,
- the content and format of the training provided, and
- its effectiveness.
Regular on-going skills and knowledge assessment: Regulation 21 required that firms carry out regular “screening” before someone is appointed to a role and at regular intervals thereafter.
Screening means an assessment of:
- the skills, knowledge and expertise of the individual to carry out their functions effectively;
- the conduct and integrity of the individual.
As an independent 3rd party who specialise in Anti-Money Laundering we can usefully contribute to this assessment.
For further information and to discuss your requirements please contact Graham Gibson on +44 (0) 1738 500 764 or email gmg@AMLHub.co.uk.