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Why is AML training important?

Staff training is a vital anti-money laundering (AML) and counter terrorist financing (CTF) control. This is because employees are a firm’s best defence against money launderers and terrorist financiers who may try to take advantage of the legitimate services offered for their own, illicit, purposes.

Failing to provide training to employees makes it easier for organised criminals to launder the proceeds of their crimes into the financial system, undermining the UK economy and can result in the firm becoming unwitting accessories to serious offences such as drug trafficking and human trafficking.

IMPORTANT: Completing regular appropriate AML training is also a regulatory requirement stipulated by the Money Laundering Regulations (MLR).

What is the purpose of AML training?

AML training given by the firm should equip employees with sufficient knowledge to effectively recognise red flags and suspicious activity.

Additionally, employees should be aware of their legal obligations to recognise and report suspicious activity.

Employees are trained to spot and report suspicious transactions and activity to make it more difficult for organised crime to launder the proceeds of crime and continue criminal activity.

If a firm is has never made an external or internal report it may be the case that employees are not sufficiently trained to spot the red flags of money laundering and suspicious activity and the firm MLRO should consider the training needs of all employees.

What does my firm need to do?

Firms must adopt a training schedule that is relevant to the accounting sector and the types of services it offers to clients.

The training programme should cover at least, but preferably more than, the following key areas:

AML red flags
law and regulations placed in the context of the firm’s business activities
conducting customer due diligence (CDD)
SARs and how to deal with suspicious transactions
Tipping-off
record keeping

Firms should retain as evidence any copies of training materials used in the delivery of AML training, such as presentation slides or recordings.

It may also be appropriate to adopt a training schedule with an assessment aspect to provide reassurance that employees have understood the objectives of the training and met required standards. This is also valuable evidence for firms when demonstrating that its employees have been adequately trained and understand the key aspects of the firm’s AML control.

Firms should also maintain a training log that records the nature of the training undertaken, date of completion, attendance, employee assessment results, and details of scheduled training.

Firms should note that during a monitoring visit evidence may be requested of employee training logs.

Are there additional requirements for MLROs?

The role of the Money Laundering Reporting Officer (MLRO) requires additional training in comparison to that of a regular employee.

MLROs must be familiar with wider AML literature produced for the accounting sector by law enforcement agencies, national government, and other bodies. MLROs should be familiar with at least, but preferably more than, the following:

Can I produce my own training material?

Members in Practice can produce their own training materials, so long as they cover the above-mentioned topics with the appropriate detail.

In addition, AIA provides webinar recordings and guidance material.

As a small practice we know all our clients personally, are we still required to do this?

AML training is a requirement for all AIA Members in Practice regardless of the size of the firm.

It is vital that all accountants are trained to be vigilant and monitor their clients for any suspicious activity, regardless of who they are; a small practice is more likely to be targeted by criminals as criminals may assume that a small firm’s AML controls will not be as effective as those of a large firm.