(AML-CFT Decision Articles 20.4-5, 21.4)

In order for their ML/FT risk assessment and AML/CFT mitigation measures to be effective, FIs should ensure that their employees have a clear understanding of the ML/FT risks that the FI is exposed to and can exercise sound judgment, both when adhering to the FI’s AML/CFT risk mitigation measures and when identifying suspicious transactions. Furthermore, due to the ever-evolving nature of ML/FT risks, FIs should ensure that their employees are kept up to date on an ongoing basis in relation to emerging ML/FT typologies and new internal and external risks. . Depending on the nature, size and level of complexity of an FI, an FI should also screen staff to ensure high standards when hiring employees.

Thus, to ensure a high level of competence and AML/CFT programme effectiveness, FIs should formulate and implement appropriate policies, procedures and controls with regard to staff screening and training. An effective training program should not only explain the relevant AML/CFT laws and regulations, but also cover the institutions’ policies and procedures used to mitigate ML/FT risks, scope of target employees such as but not limited:

These measures should be applied across organisations and financial groups, including their foreign branches and majority-owned subsidiaries. Examples of some of the factors that should be considered when determining appropriate staff screening and training measures include, but are not limited to: