Training staff is a key part of your role as money laundering reporting officer (MLRO). Training is vital for ensuring that all staff - from fee earners to the finance team - appreciate the risks facing your firm, understand money laundering warning signs, and know when to report concerns to you so that you can take action.
So, exactly what sort of training do you need to provide and how do you make sure your training sticks?
Why?
The Money Laundering Regulations 2007 require you to train relevant staff on their legal obligations and on how to recognise and deal with money laundering risks.
The SRA Handbook also requires you to give staff training that is appropriate to their work and level of responsibility.
Chapter 3.9 of the anti-money laundering (AML) practice note provides further information on your training obligations.
Who?
It can be tempting to think that your fee earners are the only people who need AML training as they are the ones dealing with clients on a daily basis.
However, when planning AML training, you should think about all the staff at your firm who are involved with clients and client funds, including your accounts and administration teams and even reception staff.
How often?
You must provide training at regular and appropriate intervals. The practice note advises that at a minimum, formal training should be given every two years for all relevant staff.
However, trends and methodologies can change and staff will struggle to keep the key warning signs at the forefront of their minds for this long, making refresher training and information alerts crucial.
Regular and on-going training is the most effective way to embed compliance. This doesn't mean that you have to provide a full training session every time. Emailing relevant articles or raising internal queries for discussion in a team meeting every few months is an excellent way of keeping AML fresh in your team's minds.
Appropriate focus
Staff will connect with training and understand how to comply with the requirements most effectively when they can actually see how it is relevant to what they do every day.
Using training examples which apply to the relevant area of practice will not only increase engagement from staff, it will be more effective in focusing their minds on the risks they really need to mitigate.
Some training tips
AML is a complex area and can be difficult to understand for those who are not directly involved with it on a daily basis. Here are a few tips to help you make sure your training sticks:
- Try to avoid giving staff chapter and verse on what the law is.
- Tailor your training to staff's areas of practice or work to help them understand why AML is relevant to them.
- Give examples to illustrate your points.
- Keep it interactive by using quizzes and asking questions
- Focus on scenarios or stories and explain the consequences. Ask for views before talking staff through the procedures and legal requirements.
- Don't just tell staff what is wrong - explain how to do things right.
Further resources
The Law Society's Risk & Compliance Service helps members with risk management and compliance. It can visit your firm and give you a free AML health-check and can also provide tailored training on financial crime prevention for your staff.
The AML e-forum includes several case studies that can be used for training purposes. If you are an MLRO and would like to join the e-forum, email antimoneylaundering@lawsociety.org.uk.