guideline on anti-money laundering and the combating of terrorist ...

Guideline on Anti-Money Laundering and the Combating of Terrorist Financing22. TRAINING AND AWARENESS22.1 An integral element of the fight against money laundering and the financing of terrorism is the awareness ofthose charged with the responsibility of identifying and analysing potential illicit transactions. Therefore, inaccordance with Regulation 6 of the FOR, financial institutions are required to ensure that its directors andstaff and appropriately trained to equip them to perform their obligations in respect of AML/ CTFrequirements.22.2 Training should be targeted at all employees but greater emphasis should be placed on the training of theCompliance Officer as well as the compliance and audit staff because of their critical role in sensitizing thebroader staff complement to AML/CTF issues and ensuring compliance with established AML/ CTF policiesand procedures.22.3 At a minimum, a financial institution is required to:a) Develop an appropriately tailored training and awareness programme consistent with their size,resources and type of operation to enable their employees to be aware of the risks associated with MLand TF. The training should also ensure employees understand how the institution might be used forML or TF; enable them to recognise and handle potential ML or TF transactions; and to be aware ofnew techniques and trends in money laundering and terrorist financing;b) Document, as part of their AML/ CTF policy document, their approach to training, including thefrequency, delivery channels and content;c) Ensure that all staff members are aware of the identity and responsibilities of the Compliance Officerand/or the Reporting Officer to whom they should report unusual or suspicious transactions;d) Establish and maintain a regular schedule of new and refresher programmes, appropriate to their riskprofile, for the different types of training required for:i. new employees;ii. operations staff;iii. supervisors;iv. board and senior management; andv. audit and compliance staff.e) Obtain an acknowledgement from each staff member on the training received;f) Assess the effectiveness of training; andg) Provide all staff with reference manuals/materials that outline their responsibilities and the institution’spolicies. These should complement rather than replace formal training programmes.Page 46 of 75