Training: The foundation of excellence
Training is the cornerstone of an effective anti-money laundering (AML) and countering the financing of terrorism (CFT) program. It creates awareness and provides the fundamentals needed for success. A well-rounded approach to training blends various techniques for comprehensive coverage.
Common training traps
Despite its importance, AML/CFT training can sometimes fall short. Some common pitfalls include using generic online courses for all employees, which lack job-specific responsibilities, and missing or not retaining attendance records and training materials.
In addition, not following up on assigned training enrollments, not escalating missing deadlines and allowing excessive attempts to pass courses can undermine the effectiveness of training programs.
Effective training tactics and techniques
Training should be supplemental to ongoing professional development. To avoid these traps, management should create records for attendance and completion, report and monitor progress, measure effectiveness through testing and set training frequency, such as annually or quarterly. Training should be specific to job roles and responsibilities, with the depth of material tailored for different positions and levels.
Ongoing training and updates
Ongoing training frequency for existing staff should be set within the financial institution’s policy (i.e., annual, quarterly or microlearning sessions). It should include a refresher on the importance and purpose of combatting financial crimes, internal policies and procedures and requirements related to specific positions and responsibilities.
Periodic updates to staff regarding policy changes, updates to procedures and practices and regular department meetings are essential. Platforms like Teams, Zoom and GoTo Webinar can be used to facilitate live training and provide an easy way to communicate periodic updates. A simple email or agenda item for a department meeting is also a great way to reach employees for quick reminders or minor procedural changes.
Who needs training?
Training is essential for:
- New hires, rehires and seasonal staff
- Existing staff
- The Bank Secrecy Act (BSA) department
- Senior management
- The board of directors
- Third parties, as applicable
It’s important to remember that trust and wealth management, seasonal, rehired employees and back-office employees (such as operations, wires and bookkeepping) should receive BSA training as well. Any employee who may potentially detect suspicious activity through transactions or customer behavior should receive training that is appropriate for their job responsibilities.
New hire training should include an overview of BSA/AML/CFT, stressing the importance and purpose of combatting financial crimes, the financial institution’s own internal policies and procedures and requirements related to the specific position.
Training records and retention
All training records should be retained back to the last exam cycle, at a minimum. This includes attendance records, onboarding materials for new hire training, completed courses reports, certificates from external training and content from webinars, course descriptions and conference agendas.
How Wipfli can help
Let us assist you in creating the most effective training program for your organization. Our regulatory professionals can assess your business’s readiness, identify gaps in your current training program and implement strategies for success. Contact us today to get started.
