© Mark A. | Finance, Financial tools | Comments Share this page:
AML & Financial Crime Compliance training needs to be more than just facts and a little quizThe scale of the fines imposed [particularly by US regulatory bodies] for AML and Sanctions breaches seems to get bigger and bigger as time passes. Historically, banks have used e-learning through their LMS to ensure compliance with existing laws and modify their internal policies & procedures to take account of new criminal schemes. This lets compliance and internal audit teams feel comfortable that staff who have passed the online tests are now compliant.
Logically though, policies and procedures are static, reactive and often fighting last year's battles. Often, by the time these have changed, the criminals have moved on to a new business sector or come up with new techniques to launder the proceeds of crime.
Regulators are increasingly turning against e-learning because of this - for example, as part of HSBC's Deferred Prosecution Agreement, they made a promise to give all staff a 1-day face to face AML & Sanctions course. Very expensive you might think but not nearly as expensive as the fine to be paid if a bank doesn't show real progress in fighting financial crime, not to mention the hidden cost of reputational risk.
AML & Financial Crime Compliance training needs to be more than just facts and a little quiz - it needs to instil amongst delegates a culture of the 'smell test'. This ensures that employees won't stop asking questions when they feel they have complied with existing policies but rather dig deeper when they are unsure about any facet of a client. Employees are after all the first line of defence and see more customers than any other part of a financial institution.
Our courses teach this 'professional scepticism' & are case study based so delegates can share information, examples [with both good and bad outcomes] and show how the constantly changing world of financial crime means all staff need to do more than tick the boxes. It is no longer a question of if regulators will get tougher on banks but when and financial institutions will need to show that their learning processes are good enough.
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