Role-Specific AML/CFT/CPF Compliance Training
Role-Specific AML/CFT/CPF Compliance Training
The Federal Decree Law and Cabinet Decision on AML/CFT and TFS compliance requires businesses operating in the UAE to impart AML/CFT compliance training to their employees. The anti-money laundering, combating the financing of terrorism, and counter-proliferation financing (AML/CFT/CPF) compliance training allows staff to detect possible unusual or suspicious transactions, activities, and behaviour. In addition, these AML/CFT/CPF training programs ensure that the staff are well-qualified, well-trained, well-equipped, and well-aware of their responsibility to prevent and combat ML/FT threats.
Role-specific AML/CFT/CPF training programs aim to equip employees with the necessary knowledge and skills required to fulfil their roles and duties effectively within their organisation’s internal AML framework. This not only enhances the capabilities of the business in preventing and detecting risks but also helps the business from being exploited by criminals, maintains its reputation, and builds customer trust in the business.
The Role-Specific AML/CFT/CPF Compliance Training Program can be categorised as follows:
General Training to New Staff (Irrespective of their role/title)
Onboarding employees is a continuous process for any business or company. Thus, businesses need to ensure that new staff hired are given general AML training, irrespective of their role or responsibilities within the organisation.
- Introduction of money laundering, financing of terrorism, and proliferation financing (ML/FT/PF) concepts and the AML/CFT/CPF legal framework. This would help staff members understand AML topologies, key AML international and national regulations and the impact of ML/FT/PF activities.
- Explain the need to identify ML/FT/PF risks in order to safeguard the business against criminal activities.
- Describe the obligation to report any identified suspicious activities and transactions to the MLRO so that the MLRO can take further action as required by law.
- Explain the offence of tipping off to make them understand the importance of confidentiality and discretion in reporting suspicious activities (“tipping off”).
Frontline staff:
Frontline staff play a crucial role in the business’s AML/CFT strategy due to their role as the first point of contact with customers.
- Explain the importance of the frontline staff in the regulated entity’s AML/CFT strategy and maintaining regulatory compliance. By helping them outline their responsibilities, they can understand AML measures and implement them effectively.
- As frontline staff interact directly with customers, they must know internal policies and procedures in relation to KYC, CDD, and record-keeping, which helps them verify customer identities, assess risks, maintain accurate records, and keep compliance efforts.
- Discuss and establish red flags and common ML/TF typologies. This will enable front-line staff to take a proactive approach to identify illicit activities and equip employees to be aware of transactions that deviate from normal behaviour.
- Describe policies and procedures for reporting suspicious activities and transactions, as well as steps involved in filing the internal SAR/STR. Explain the tipping-off provisions so that they don’t end up informing their decision to file SAR/STR to suspicious customers and others.
- Explain the concept of targeted financial sanctions and their purpose, the implications of non-compliance, and screening procedures. This will help employees better understand TFS obligations and prevent transactions with sanctioned individuals or entities.
- Discuss strategies and guidelines for maintaining client relationships after filing a SAR/STR. This will help businesses in managing client relationships post-filing of a SAR/STR, which requires sensitivity.
Compliance Team:
Compliance Team plays a key role in supporting and facilitating communication across the entire office.
- Explain the meaning of Ultimate Beneficial Owners (UBOs), their significance in due diligence, and the procedure to identify and verify UBO information. With such a program, AML/CFT compliance staff would be able to assess the risk associated with UBOs and ensure compliance with AML/CFT regulations.
- Outline and discuss the procedure of Customer Due Diligence, Enhanced Due Diligence, and Customer Risk Assessment. As compliance staff is responsible for conducting these procedures, employees can effectively employ a risk-based approach to mitigating customer-related risks by understanding them.
- Explain the purpose and scope of Targeted Financial Sanctions, identify sanctions lists, describe screening procedures, and the consequences of non-compliance. Understanding TFS is critical due to the role of compliance staff in preventing transactions with sanctioned individuals or entities.
- Discuss the importance of ongoing monitoring of a business relationship and outline techniques and tools for the same. Compliance staff ensure ongoing monitoring; thus, with this training, they can promptly identify and evaluate potential risks and take action that may require further investigation.
- Describe the organisation’s transaction monitoring procedures and explain automated and manual review procedures. Understanding transaction monitoring procedures enables staff to detect suspicious activities and patterns, allowing timely intervention and reporting.
- Explain the regulatory reporting procedures around SAR, STR, HRC, HRCA, DPMSR, REAR, FFR, PNMR, AIF, AIFT, RFI, and RFIT.
- Explain the mandatory record-keeping requirements and types of records to be maintained, their storage and security-related aspects.
Managers:
Managers oversee the business environment and assign and assess what each employee is doing. Their role is crucial within AML compliance as they know the individual roles and responsibilities of employees.
- Explain key AML/CFT laws and regulations, regulatory obligations specific to the organisation’s business operations, and the consequences of non-compliance. Such training is necessary due to the managers’ role in ensuring organisational compliance and creating a compliance culture.
- Customise and provide specific training around AML/CFT compliance requirements, considering the nature of the business and the regulatory environment governing it. Such tailored training ensures that managers understand AML/CFT compliance requirements of the regulatory environment in which it operates.
- Explain the purpose and benefits of the Enterprise-Wide Risk Assessment. A better understanding of conducting EWRA enables managers to identify, assess, and mitigate AML/CFT risks across all facets of the organisation’s operations.
- Explain the purpose and scope of Targeted Financial Sanctions, identify sanctions lists, describe screening procedures, and the consequences of non-compliance.
- Training around supervision of the overall compliance function and helping them understand the role of monitoring and AML measures in strengthening the AML/CFT compliance framework. This training is important as managers oversee the organisation’s compliance function, ensuring that AML/CFT policies and procedures are effectively implemented and adhered to.
- Explain and describe the objectives for conducting health checks and internal audits. Managers would be better able to understand the importance of health checks and ensure that the required data is made available for the same. They would also be able to implement recommendations and corrective actions to address identified deficiencies.
- Explain regulatory reporting requirements and discuss the implications of inaccurate or delayed regulatory reporting. This is important for timely and accurate reporting of AML/CFT activities to regulatory authorities, demonstrating transparency and compliance with regulatory obligations.
- Insights into the AML software available in the market for compliance automation.
Compliance Officer/Money Laundering Reporting Officer (MLRO):
Compliance Officers (CO)/MLROs have the most important role as they work to combat financial crime in their businesses. Thus, for efficient implementation of AML frameworks within their organisation, businesses must conduct training for MLRO, which:
- Elements of the latest National Risk Assessment (NRA) addressing the risks associated with the business sector, emerging typologies and guidance provided by the authorities.
- Training on procedures for assessing and analysing internal Suspicious Activity Reports (SARs), Suspicious Transaction Reports (STRs), and other regulatory reports. This enables the MLRO to detect trends, patterns, and emerging risks.
- Training focused on the guidelines for submission of regulatory reports on the UAE FIU’s goAML portal and tipping-off provisions so that MLRO understands any compliance gaps.
- Training to keep abreast of AML/CFT regulatory changes and global best practices. With such training, MLRO would be able to enhance the overall capabilities of the business’s AML framework.
- Compliance Officer’s duties towards the government and the employer.
Furthermore, businesses may conduct these programs online, in classroom training, or in hybrid mode. Each of these modes of training has its own speciality and advantages. Therefore, businesses must figure out which mode is suitable for which role for better performance.
About AML UAE
AML UAE can help your business empower your team against financial crime with role-specific AML/CFT/CPF compliance training. With our tailored approach, your business can equip your employees with the knowledge and skills to identify and mitigate risks effectively. Strengthen your business’s defences and uphold regulatory compliance with AML UAE training programs.
