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Qn5Assignment: (how (various stages (recruitment requirements (such as…
Qn5Assignment:
how
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various stages
- recruitment requirements (such as referencing procedures, base qualifications)
- induction training
- attaining competence process
- maintaining competence process
- supervision framework.
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case
August 2007, American Express Bank International entered into a deferred prosecution agreement with the US Department of Justice and forfeited US$55 million to resolve US Bank Secrecy Act violations
The Bank Secrecy Act requires,
among other things, an on-going employee-training programme.
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measures to assess
before assessing effectiveness, must first assess compliance risks & issues (pg 236)
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issues
relevancy
Common complaints about AML training are that it is either too generic or lack practical relevance. For example, there is very little, if any, point in showing an AML training video designed for offshore private banking sector to staff of an OTC derivatives structuring desk.
A compliance professional should play an important role in ensuring that AML training is relevant. One way of doing this is by using ‘sanitised’ examples of internal
suspicious transaction reports.
Many firms make the mistake of assuming that staff members are competent to
undertake their responsibilities because they have passed industry-recognised
examinations
Although examinations are useful in imparting standardised
technical information, they do not deal with educational needs relevant to each
firm’s unique policies and procedures, nor do they ensure that staff members have
the necessary practical skills to undertake their roles.
issues to consider
Reduce the ‘authority gradient’ between them and the trainees. A training
session is not an exercise in demonstrating knowledge but an exercise in
trainee learning. If the gap between the officers and the trainees is too large,
the message will not be absorbed.
Avoid lecturing. Instead, encourage audience participation. The more
‘personalized’ a training message, the more likely the message will form part
of a trainee’s long-term memory.
Attention spans are very short. Speaking for longer than 20 minutes without
audience participation means most of what is said will not be absorbed.
Encourage all training contributions by praising lavishly.
Use visual aids whenever possible. Most of what trainees learn comes from
what they see, not from what they hear.
In the case of all new employees who are engaged in the provision
of financial services, an assessment of their training needs should be
conducted at the recruitment or induction stage. A training plan should be
formulated so that individual needs are met.
elements
objectives
11.9
- Encouraging staff to be vigilant at all times.
- Making staff aware of their legal obligations.
- Demonstrating why relevant products and services are vulnerable.
- Educating staff in the recognition of unusual/suspicious transactions.
- Making staff aware of the organisation’s AML policy and procedures
Educating staff in the importance of KYC information and client due diligence.
- Enabling staff to identify the MLRO and the deputy MLROs.
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when
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good practice for MLROs to ensure
that adequate training provision is made for new employees shortly after the commencement of their employment, and that additional training is givenwhere necessary
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Effectiveness
Until the salesperson, the Client On-boarding Officer and the AML Compliance team all understand the bigger picture in regards to money laundering and terrorist financing, we will continue to see short term commercial gain prioritised over meaningful Customer Due Diligence and AML controls
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How short-term training to the staff in key business units can be organised and the elements of a successful programme and measures to assess the impact of training. (mod 4)
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