16.17.1The Licensed Person must provide comprehensive AML/CFT compliance training to all employees including its Manager in Charge, functional heads, Directors of the Board and Owner/Partners/Shareholders. The Licensed Person is required to coordinate with the FID regarding such training;
16.17.2The AML/CFT compliance training must be provided to all new joiners within thirty (30) calendar days from the date of joining. The new joiners must not be allowed to serve any customer independently until they have successfully completed such training. Refresher training must be provided to all employees at regular intervals;
16.17.3The frequency of refresher AML/CFT compliance training may be determined based on the ML/FT risk exposure of each employee. Employees who deal directly with customers, products or services must be trained at least annually at a minimum;
16.17.4Refresher training must also be provided whenever there are changes in the AML Laws, Regulations, Notices, the Standards or the Licensed Person’s AML policy/procedures;
16.17.5Appropriate processes must be implemented to periodically assess the AML/CFT awareness of employees and repeat training must be planned based on the result of such assessment process;
16.17.6Appropriate AML/CFT training registers must be maintained in order for the Central Bank Examiners to verify the training history of each employee;
16.17.7Evidence for all trainings conducted such as, the training policy, training materials, training register, training plan, training schedules, assessment sheets, training certificates, etc. must be retained for the verification by the Central Bank Examiners;
16.17.8The AML/CFT training materials must be reviewed and updated at regular intervals or whenever there are changes in the AML Laws, Regulations, Notices, the Standards and the Licensed Person’s AML Policy/ Procedures; and
16.17.9The AML/CFT training materials must cover, at a minimum:
a)Money laundering and terrorist financing, definitions, typologies as well as recent trends;
b)ML/FT risks associated with the products and services offered by the Licensed Person;
c)AML/CFT policies and procedures including the highlights on recent changes;
d)The regulatory responsibilities and obligations of employees under AML/CFT Laws, Regulations, Notices and the Standards;
e)Description of Know Your Customer process and its importance;
f)Due Diligence measures and procedures for monitoring transactions;
g)Sanction screening and FPEP screening procedures;
h)Red flags to identify unusual transactions or transaction patterns or customer behaviours;
i)Processes and procedures of making internal disclosures of unusual transactions;
j)Roles of the Compliance Officer and Alternate Compliance Officer including their full contact details;
k)Tipping off;
l)Record retention policy;
m)Reference to industry guidance and other sources of information;
n)Emerging ML/FT risks and measures to mitigate such risks;
o)Penalties for non-compliance with the AML/CFT Laws, Regulations, Notices and the Standards; and
p)Disciplinary procedures to be applied on employees for not adhering to the AML Policy and Procedures.