ECSH33220 - Anti money laundering training

Introduction

After checking the risk assessment ,establishing the policies, controls and procedures (PCPs) and the communication of the PCPs, you should establish what anti-money laundering, counter terrorist and proliferation financing (AML/CTF/CPF) training is provided to staff.

Training is required by regulation 24 of the Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulations 2017 (MLR 2017) to ensure relevant staff are:

  • Made aware of the law relating to money laundering, terrorist financing and proliferation financing (ML/TF/PF), and to the requirements of data protection relating to MLR 2017.
  • Regularly given training in how to recognise and deal with transactions and other activities or situations which may be related to ML/TF/PF.

You must ensure you read the technical guidance in ECSH63415 Regulation 24 - Training.

 

What the anti-money laundering training must include

You must establish what the training includes and ensure it meets the requirements of regulation 24 of the MLR 2017. Follow the “What to establish” section in ECSH 63415 Regulation 24 – Training.

You should consider if the training adequately provides the following:

  • The requirements of MLR 2017, Part 7 of the Proceeds of Crime Act 2002 and sections 18 and 21A of the Terrorism Act 2000.
  • Information on how to recognise and deal with transactions or other activity which may be related to ML/TF/PF.
  • Information on what suspicious activity could look like? See sector specific risks and red flag indicators published in the sector guidance on GOV.UK.
  • Information on what to do when customer activity raises suspicion.
  • Data protection requirements.

 

Different types of anti-money laundering training 

MLR 2017 are not prescriptive in the type or form of training which is to be provided to staff. You should be aware that training may include:

  • face to face training sessions
  • online training sessions
  • HMRC webinars
  • going to conferences
  • attending internal meetings to discuss the business procedures
  • reading relevant publications
  • meetings to look at the issues and risks.

Please note that this is not an exhaustive list of training. You may find that a business uses a combination of different types of training depending on the size, nature, and structure of the business. Some businesses also use external providers to deliver training.

There is also e-learning available to businesses on GOV.UK. It is found in the same place as the HMRC webinars. The e-learning available is referenced as "guidance" but are training modules. They vary in length based on the sector and the subject being discussed. You should review the link and then ensure that you also provide it to and discuss it with the business.


Who needs to be trained

The business must make sure that relevant employees and agents, whose work is described in regulation 24(2), are trained.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)


When is anti-money laundering training needed

MLR 2017 is not prescriptive on when training must be provided or how frequently. You should establish when training is given to new starters and how learning is reviewed and updated. This may include any updates to the legislation, staff changing roles, new products or services, or any changes to the business’s risk assessment, policies, controls or procedures.

It is for the business to determine how often staff and agents are trained. 

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)