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Requirements
All regulated firms are required under the Money Laundering Regulations to give all “relevant” staff appropriate training on money laundering prevention. The Rules place responsibility on the MLRO for ensuring that awareness and training of staff is maintained and documented.
This section of MLRO.net focuses on providing training for new employees, or for existing employees whose level of training has not been clearly documented.
All new employees, irrespective of the level of seniority, should receive induction training covering:
- understanding of money laundering and the ways in which their own organisation may be vulnerable
- statutory and regulatory responsibilities on individuals and the firm
- procedures for reporting any suspicions to the MLRO
- potential consequences of failing to meet their obligations on the prevention of money laundering and terrorist financing
Additionally, new employees should be advised of the importance of money laundering prevention to your organisation, and the need for Know Your Customer procedures to be in place.
Training Techniques
As the Joint Money Laundering Steering Group Guidance Notes state, "there is no standard preferred way to conduct staff training", and therefore the MLRO will have to consider the most appropriate approach for his/her institution.
There are several approaches to training:
Training videos
As a training technique, video is effective in raising awareness. For best results, video needs to be used as part of a small, interactive, group training session.
The following training videos are particularly suitable for induction training:
> Down to You New!
> Money on the Move
> Innocent Parties
E-learning
Computer-based, web-based, or multi-media training programmes provide individual training at the convenience of the trainee, and can record the training date, nature of the training and the names of staff who have received the training. This can be helpful in meeting the FSA’s requirement to keep detailed records of all money laundering training. The demonstration of competency levels through the use of computer-based testing facilities is likely to become an increasingly important feature as the regulators take greater interest in the competency of financial sector staff.
The following e-learning programmes are particularly suitable for induction training:
> Training on Record
> Training on Record - Offshore
> Training on Record - Law Firms
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