To learn more about our upcoming public AML & CTF training courses click here.
To learn more about our tailored in-house training solutions on AML & CTF click here.
To learn more about how we train and who we have trained click here.
Why educate and train staff on the importance of AML & CTF?
Firstly, an effective AML & CTF educational training programme is a legal requirement and secondly, education helps a firm to know, measure and control its compliance, operational and reputational risk. Therefore education of directors, management and staff is a vital element in every AML & CTF compliance programme.
US and UK regulatory authorities have penalised many international firms, including affiliates of Australian firms, for failing to properly and adequately implement AML & CFT programmes. A number of these US, UK and other European firms were fined for, amongst other failures, failing to properly train staff on AML & CTF.
In September 2004 Bank of Ireland was the first firm fined (£375,000) by the UK Financial Services Authority for failing to ‘effectively’ train staff on AML (click here for the briefing note). In December 2005 ABN AMRO was fined ($80 million) and ordered to remedy its worldwide banking operations to effectively implement AML & CTFcompliance and risk management systems to ensure adequate oversight, effective risk management and full compliance with applicable U.S laws and regulations (click here for the FINCEN press release). In both cases, the relevant regulatory authority penalised a firm whose head office was located outside of the regulator’s jurisdiction. So why did both firms comply? Because failing to comply would have potentially led to these two firms losing access to large foreign capital markets. Suddenly AML & CTFwas elevated in the minds of senior management from being simply a ‘compliance department issue’ to a core operational risk for senior management to identify, assess and review on a regular basis.
And it is not just overseas firms that have been sanctioned. Recently, in September 2007, National Australia Bank remitted $100,000 to settle allegations of violations of US OFAC enforced regulations (click here for the OFAC press release). Readers will note that the OFAC press release recognises the ‘significant remediation’ work undertaken by NAB, including major upgrades to its worldwide compliance policies, as well as the fact that the violations were voluntarily disclosed. NAB’s action mitigated the potential penalties for the alleged violation by nearly 90%.
AUSTRAC, the Australian government AML & CTF regulator, provides a useful and free on-line AML/CTF tutorial on its website. The tutorial is currently located at http://www.austrac.gov.au/elearning/mod_modules.html.