Firms always struggle with this. Rachael Eyre asks: how much AML training is enough? How much is too much?
What counts as AML training?
There is no universally recognised ‘best’ format for AML training. Putting together and delivering training eats up resources – not least in the time spent preparing and fee-earning hours lost in the training room. That’s why ‘on demand’ services are becoming ever more popular.
The format for AML training could include:
- Large group ‘traditional’ training sessions
- Webinars (live and recorded)
- Podcasts
- Conferences
- Online courses
- Briefings delivered by email
- Small group workshops
Who needs to be trained?
Anyone who has a part to play in your anti-money laundering processes. Be it the reception staff using the ID verification systems, the solicitors running the cases, the managers supervising the departments or the compliance officers with overall responsibility for compliance. They each have an important role, although arguably the training they receive should be tailored to reflect their position.
AML training should be risk based
Training content and frequency should be guided by your firm’s risk exposure. The logical place to start is the Firm Wide Risk Assessments (aka Practice Wide Risk Assessment). For those firms caught by the Money Laundering Regulations, the risk assessment is the cornerstone of AML compliance. It will identify where the training should focus.
The higher the risk identified (think conveyancing and complex corporate), the tighter your AML controls should be. Training will be a big part of that. The MLRO will need to be confident that suspicions and queries will be raised by the team.
Also consider real life risks. If the team routinely struggles on Source of Funds issues, for example, that should be a training priority. Had to make a suspicious activity report? Use that to highlight what was done correctly, and where lessons can be learned.
So, how often?
Higher risk firms are likely to ensure that some form of auditable AML training takes place every year, with additional reminders and briefings in between.
Lower risk firms will be able to get away with less regular formal training. The old rule of thumb was every two years or so, which for some firms will still be about right.
Do be alive to other relevant trigger points for training. New staff induction is an obvious one – who knows when and how thoroughly their last firm provided training. And whenever there is a material change to the AML regime or your firm’s internal policies should also prompt a training review.
