The Money Laundering Regulations 2017 require relevant businesses to:
- Make employees aware of the laws relating to money laundering and terrorist financing
- Regularly provide training on how to recognise and deal with transactions and other activities which may be related to money laundering or terrorist financing
What is a relevant business?
Money laundering regulations apply to various business sectors, including financial services, accountants and estate agents, and other businesses such as law firms undertaking regulated work.
Every business covered by the regulations must be supervised, and register with HMRC if not already covered by a professional body such as the Law Society.
The money laundering regulations apply to the following areas:
- High value dealers
- Trust or company service providers
- Accountancy service providers
- Estate agency businesses
- Money service businesses
- Bill payment service providers
- Telecommunication, digital and IT payment service providers
Training requirements
Staff training is one key component of systems and controls designed to ensure there are adequate and robust measures to prevent money laundering.
Staff training should be given at regular intervals, and details recorded. Training records should include:
- A copy of the training materials
- Details of who provided training, if provided externally
- A list of staff who have completed training, with dates, and their signatures, confirmation of their understanding of the obligations or electronic training records
- An updated training schedule
Training needs to include procedures to spot and deal with situations that suggest a heightened money laundering risk. Higher risk accounts and customers will require staff dealing with them to undergo enhanced or more frequent training.
How often should staff be trained?
At a minimum staff must be trained at least once every two years on money laundering. However, there are a number of factors that should trigger an additional need for training.
- When staff join the business
- When staff move to a new job
- When staff change roles in an organisation
- When a change happens in the legislation
- When a change in the level of risk occurs
VinciWorks would recommend all staff undertake money laundering training annually, with higher risk staff undergoing refresher training after six months.
CPD training
Money laundering and terrorist financing training can also be part of CPD training staff wish to undertake. Reading news articles on money laundering, reviewing examples of money laundering cases and undergoing brief knowledge checks at regular intervals will also go a long way.
VinciWorks’ AML products
In addition to our suite of online training courses, we also have some useful free compliance tools.
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Fourth Directive ready anti-money laundering and counter-terrorism financing policy template
- Mini course on the Fourth Money Laundering Directive
VinciWorks’ risk-based course, Anti-Money Laundering: Know Your Risk
VinciWorks has recently released a new course on anti-money laundering. The course takes the risk-based approach mandated by the Fourth Money Laundering Directive and drops users into real life, scenario-based questions to test their knowledge, understanding and ability to uncover risks. You can demo the course by clicking on the button below.
