February 3, 2021

Picture credit Pixabay.com

Webinar:

Prioritising AML Training

Webinar – February 3, 2021

Prioritizing AML Training - Speakers

Effective & Relevant AML Training

Across the Organization

Chowdhury MAQ Sarwar

Independent Consultant

(Former Chairman AACOBB)

◼ Banks & financial institutions rely heavily on their diligent workforce as defense against money laundering and terrorist financing.

◼ Every employee within the institution must know his or her respective role, and be able to perform it.

◼ Ensuring your employees are adequately trained in anti money laundering (AML) is a crucial component of managing financial crime risk.

◼ Proper AML training not only needs to be comprehensive, up-to-date, and participatory, it also needs to be performed regularly for every single employee having an AML role not just customer facing employees.

◼ There have been many enforcement actions for training deficiencies where Banks were fined for failing to provide appropriate training for specific positions, departments, board members and other personnel.

AML Training

◼ While a large population of employees need AML training, curriculum should be tailor made to develop the essential skills necessary to perform different roles in the front, middle and back offices.

◼ Basic AML awareness training for all to understand how to support their FI in Anti-Money Laundering and countering terrorist finance and how to prevent, detect, and report money laundering activities.

◼ Targeted training for financial crime risk specialists and business/operations staff in Front, Middle & Back offices on Know your Customer (KYC), the importance of Customer Due Diligence (CDD), Screening, Sanctions & Transaction Monitoring, TBML, etc according to their respective roles.

◼ AML Awareness Training for the Board and top management.

Target Audience for AML Training

◼ Overview of the key AML laws, regulations the other requirements .

◼ Training should also be custom-tailored to each institution’s unique risk profile.

◼ The training program should also cover day-to-day compliance responsibilities including how to recognize red flags in transactional activity.

◼ What to do once potentially suspicious or illegal activity is identified, who is responsible for what within the institution, what should be recorded, and consequences for non-compliance and potential penalties.

◼ Every new employee must receive training within a certain period of being hired, and everyone who works with customers, institution-wide, must receive updated AML training at least annually.

◼ Training programs should be constantly updated to reflect new realities.

AML Training Curriculum

◼ AML Governance Framework for Banks

◼ AML/CFT Responsibilities and Accountabilities

◼ Risk Based Approach

◼ Customer’s KYC/CDD and On-boarding Procedures

◼ On-going /Periodic KYC /CDD Review Process

◼ Beneficial Owner and UBO unwrapping process

◼ PEP and EDD Procedures

◼ Monitoring & reporting requirements under AML/CFT regulations

◼ Suspicious Activity/Transaction Identification & Reporting Procedures

◼ Screening & Transactions Monitoring,

◼ Red Flags

AML Training Traditional Topics

◼ 98 Does the Entity provide mandatory training, which includes :

◼ 98 a Identification and reporting of transactions to government authorities

◼ 98 b Examples of different forms of money laundering, terrorist financing and sanctions violations relevant for the types of products and services offered

◼ 98 c Internal policies for controlling money laundering, terrorist financing and sanctions violations

◼ 98 d New issues that occur in the market, e.g., significant regulatory actions or new regulations

◼ 98 e Conduct and Culture

◼ 99 Is the above mandatory training provided to :

◼ 99 a Board and Senior Committee Management

Training & Education Section of Wolfsburg CBDDQ

◼ 99 b 1st Line of Defence

◼ 99 c 2nd Line of Defence

◼ 99 d 3rd Line of Defence

◼ 99 e 3rd parties to which specific FCC activities have been outsourced

◼ 99 f Non-employed workers (contractors/consultants)

◼ 100 Does the Entity provide AML, CTF & Sanctions training that is targeted to specific roles, responsibilities and high risk products, services and activities?

◼ 101 Does the Entity provide customised training for AML, CTF and Sanctions staff?

◼ 102 Confirm that all responses provided in the above Section TRAINING & EDUCATION are representative of all the LE's branches

Training & Education Section of Wolfsburg CBDDQ

◼ AML training which creates a culture where learning is fun and enjoyable, and engages the trainers interactively

◼ Using technology to deliver training having user interface: online, e-learning, etc.

◼ Creating small discussion groups of trainers on Whats App and other Aps

◼ Providing visual information such as videos and other graphical representations of processes, procedures, laundering schemes, and terrorist methods to keep the resources' attention and retention of information.

◼ Changing the tick box attitude of somehow having everyone successfully completing AML training to making trainees believe it is of benefit to them and will make their jobs easier and more productive.

◼ Making AML training relevant to the actual issues and pain points that your institution is experiencing.

Effective AML Training Techniques

9

Thanks

Prioritising AML/CFT Training

2

• The FATF typologies studies/national

assessments indicate that criminal

organizations and terrorist groups are

exploiting vulnerabilities in the system

to move value for illegal purposes

• Meeting regulatory expectations and

demonstrating a compliance culture

including ensuring that their staff are

adequately trained

• Improving knowledge contributes to

better implementation of measures

• Sharing experiences and developing

best practices strengthens operations

• To understand global standards and

how they help combat ML/TF

• Learning platforms to feature webinar

recordings, online courses and

assessment tests

T R A I N I N G A G E N D A - A P R I O R I T Y

• To combat ML/TF threats across jurisdictions, laws and regulations have been enacted making reporting entities

responsible for preventing/ mitigating ML/TF

• A lack of AML training and enforcement failures result in monetary fines/ penalties as well as

reputational/operational/legal damage

3

• New Joiners

• On-going training programme for staff with different

training focus’ for frontline staff, compliance staff, etc.

• Audit functions with trained personnel

• Risk awareness to board members, executive directors

and consultants/contractors, if applicable

Employee Tra in ing( 3 l e ve l s o f d efe n s e )

• AML/CFT policies, procedures, controls

• Laws & Regulations

4

• Trainings on vu lnerabi l i t ies , M L/FT typo log ies

( i . e . methods , t rends a nd

tec hn iques ) , red f la g ind icators &

sa n i t i zed ca se stud ies

• INDUCTION

• ONLINE

• IN-HOUSE

• INFO • EXTERNAL

• ON THE JOB

E-Learnings and online training courses; Best Practices

Papers, Guidance Notes

Instructor led in-house training

Conferences, Seminars etc.

Training for new employees and employees taking

on new roles

Ongoing communication to employees such as

bulletins, newsletters, e-mails etc.

Specific to certain roles based on the risks

Types Of Tra in ing

C h a l l e n g e s V s S o l u t i o n s

5

• CHURN/

ATTRITION

• Induction Training

• Badges for differing levels to be devised; Basic, Intermediate, Advanced, Master, Grand Master

• DIFFERING

AUDIENCES

• Risk-based solutioning for Compliance/Audit/Sales/Customer Service/Operations;

• Typologies like TBML - Global - Trade services departments and personnel;

• Calendarized Trainings & Training Manuals

• RECORD

KEEPING

• Systemized attendance, test scores, feedback, etc. for Management Information

• Training schedule completion, pendency, levels, trainers, etc.

• ATTENTION

SPAN

• Use of Infographics, videos, doodles

• Concise & quality material

• COST &

CULTURE

• Enforcement actions to be highlighted

• Train the trainer

6

LEARNING NEVER STOPS!

THANK YOU!

ANY QUESTIONS?

THE EVOLVING ROLE OF THE COMPLIANCE PROFESSIONAL

Shirish PathakManaging Director, Fintelekt

THE EVOLVING ROLE OF THE COMPLIANCE PROFESSIONAL

COMPLIANCE ECOSYSTEM MATURITYEach country is only as strong as its weakest institution

RECENT TRENDSTraining needs to be aligned with changing trends

DEALING WITH UNCERTAINTYSocial, political and economic trends impact financial crime

SEEING THE BIGGER PICTURENeed to factor in a deep understanding of risk not justwithin the institution but across the supply chain

Influencer / Champion

Advisor / Guardian

Interpersonal / Negotiator

Team Builder / People Person

Technical Expert / Policy Maker

EFFECTIVE IMPLEMENTATION OF STANDARDSUnder-supervised and under-trained institutions contributesignificant risk to the entire financial system

EXPECTATIONS FROM COMPLIANCE

DO NOT WAIT TO IMPLEMENT AN ENTERPRISE-WIDE TRAINING PROGRAM UNTIL A REGULATORY PENALTY APPEARS

ADVOCATE COMPLIANCE IN THE RIGHT SPIRIT ACROSS THE INSTITUTION

PRESCRIBE CONTINUOUS ROLE-SPECIFIC, PRACTICAL LEARNING

FACTOR IN THE LATEST TRENDS AND TYPOLOGIES INTO YOUR TRAINING PROGRAM

www.fintelekt.academy

THANK YOU!

Please visit our new learning platform Fintelekt.Academy for AML/CFT learning resources.