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Financial institutions will find it particularly challenging right now to ensure that staff understand the full details of their AML compliance program
In this first in a series of articles, Justin Muscolino, GRC Solutions' Head of North American Training Operations, considers the challenges the situation poses for remaining compliant. He offers three ways to meet them.
The changes taking place in and to our work environments in 2020 have come to represent a new normal. Financial institutions will find it particularly challenging right now to ensure that staff understand the full details of their AML compliance program. While these programs are all too easily overlooked in the current circumstances, we need them more than ever.
Many staff are still working from home, far from their place of work. But does working from home mean that we no longer have to fulfil our work responsibilities? The obvious answer is no. Staff need to be reminded of their obligations when it comes to carrying out their job functions.
The same logic applies to our AML obligations. Staff need to be continuously trained and to have their knowledge refreshed, to reinforce the key elements of an AML compliance program, and to be reminded about what could happen if it is not followed.
When I look at AML training, or any training for that matter, I think of the need to highlight where any gaps or risks may be occurring and the importance of remediating them as soon as possible. This means that an organisation must review each component of its AML compliance program and check whether its staff are following through on them.
So, the big question is, what do financial institutions have to do to stay compliant? Let us look at some of the goals of a solid program:
Having a solid system in place will assist staff to spot the red flags of money laundering. If staff are not looking for these red flags, or if issues are not being fixed, this could put a financial institution in a bad situation.
If staff members are not focusing on any red flags that are becoming routinely noticeable, this could really hamper or increase the risks in your organisation.
There needs to be follow-up with staff members to ensure they are performing their roles, and to see if refresher training, based on real-life circumstances of non-compliance, is necessary.
This should never stop, even in the current environment. You need to perform due diligence on clients by asking the appropriate questions and looking for any obvious patterns of impropriety.
These are just a few of the areas that can pose real threats to a financial institution. There are many more.
The point is that everyone bears responsibility for compliance obligations and needs to know that they are accountable for their actions. One compliance issue alone can result in years of regulatory scrutiny, fines, and huge reputational damage. Training is an important element to address money laundering risk for the following reasons:
Anti-Money Laundering - covering the responsibilities of financial services and other businesses in general
AML/CTF Training for Finance Sector - covering the particular responsibilities of ADIs
Putting your own stamp on compliance training - quickly and within budget
This article interprets aspects of John Keller’s ARCS Model of Motivational Design in relation to compliance training. It discusses four main areas to focus on and provides simple tips to help motivate staff so that they complete and participate in mandatory compliance training. Lyndon Lovell is an instructional designer and consultant at GRC Solutions with over 16 years’ experience in governance, risk and compliance publishing and training.
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