|
Requirements
In order to comply with the Money Laundering Regulations and the FSA Rules, institutions should give managers and staff both initial basic training and on-going refresher training.
This section of MLRO.net focuses on providing refresher training for employees who have already been exposed to the subject of money laundering.
On-going refresher training is needed to update staff on the latest developments, to reinforce their initial basic training, ands to motivate on-going vigilance and compliance.
The FSA Rules specify that training must be delivered within a 24-month period, but institutions are able to set their own standards of frequency.
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 refresher training:
> Down to You New!
> Provenance
> Money on the Move
> Innocent Parties
> See No Evil
> Strictly Private
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 refresher training:
> Training on Record
|
