AML Training

AML Training

(AML-CFT Decision Articles 20.4-5, 21.4), In order for their ML/FT risk assessment and AML/CFT mitigation measures to be effective, DNFBPs should ensure that their employees have a clear understanding of the ML/FT risks that the DNFBP is exposed to and can exercise sound judgment, both when adhering to the DNFBP’s AML/CFT risk mitigation measures and when identifying suspicious transactions. Furthermore, due to the ever-evolving nature of ML/FT risks, DNFBPs should ensure that their employees are kept up to date on an ongoing basis in relation to emerging ML/FT typologies and new internal and external risks. Depending on the nature, size and level of complexity of a DNFBP, a DNFBP should also screen staff to ensure high standards when hiring employees. Thus, to ensure a high level of competence and AML/CFT programme effectiveness, DNFBPs should formulate and implement appropriate policies, procedures and controls with regard to staff screening and training.
An effective training program should not only explain the relevant AML/CFT laws and regulations, but also cover the institutions’ policies and procedures used to mitigate ML/FT risks, scope of target employees such as but not limited:
  • Customer-facing staff.
  • AML/CFT compliance staff.
  • Senior management and board of directors
These measures should be applied across organisations and financial groups, including their foreign branches and majority-owned subsidiaries. Examples of some of the factors that should be considered when determining appropriate staff screening and training measures include, but are not limited to:
  • The results of the NRA and other topical risk assessments
  • The nature, size, complexity, and risk profile of DNFBPs’ sectors and businesses, as well as those associated with the products and services they offer and the markets and customer segments they serve;
  • Effective screening and selection methods in relation the AML/CFT cultural compatibility of their employment candidates;
  • Assessment of staff AML/CFT competency in relation to training and development needs;
  • The type, frequency, structure, content, and delivery channels of AML/CFT training programmes and development opportunities;
  • The effective identification, deployment and  management of both internal and external training resources;
  • Appropriate methods and tools for assessing the effectiveness of staff hiring, training, and development  programmes, including screening procedures to ensure high standards when hiring employees.
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