AMLG 6.2.1 Appropriate AML/CFT training programme to be delivered

(1) A firm must identify, design, deliver and maintain an appropriate ongoing AML/CFT training programme for its officers and employees.
(2) The programme must ensure that the firm's officers and employees are aware, and have an appropriate understanding, of:
(a) their legal and regulatory responsibilities and obligations, particularly those under the AML/CFT Law and these rules;
(b) their role in identifying and preventing money laundering and terrorism financing, and the liability that they, and the firm, may incur for:
(i) involvement in money laundering or terrorism financing; and
(ii) failure to comply with the AML/CFT Law and these rules;
(c) how the firm is managing money laundering and terrorism financing risks, how risk management techniques are being applied by the firm, the roles of the MLRO and Deputy MLRO, and the importance of CDD and ongoing monitoring;
(d) money laundering and terrorism financing threats, techniques, methods and trends, the vulnerabilities of the products offered by the firm, and how to recognise suspicious transactions; and
(e) the firm's processes for making internal suspicious transaction reports, including how to make effective and efficient reports to the MLRO whenever money laundering or terrorism financing is known or suspected.
(3) The training must enable the firm's officers and employees to seek and assess the information that is necessary for them to decide whether a transaction is suspicious.
(4) In making a decision about what is appropriate training for its officers and employees, the firm must consider:
(a) their differing needs, experience, skills and abilities;
(b) their differing functions, roles and levels in the firm;
(c) the degree of supervision over, or independence exercised by, them;
(d) the availability of information that is needed for them to decide whether a transaction is suspicious;
(e) the size of the firm's business and the risk of money laundering and terrorism financing;
(f) the outcome of reviews of their training needs; and
(g) any analysis of suspicious transaction reports showing areas where training needs to be improved.
Examples
1 training for new employees needs to be different to the training for employees who have been with the firm for some time and are already aware of the firm's policies, processes, systems and controls
2 the training for employees who deal with customers face-to-face needs to be different to the training for employees who deal with customers non-face-to-face.
(5) Subrule (4) does not limit the matters that the firm may consider.
Derived by QFCRA RM/2019-9 (as from 1st February 2020)