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8. A Malaysian Banking Perspective: Training Requirements

Last week, I highlighted three of what I felt were important obligations and responsibilities of a Reporting Institution (RI), in this case, banks under Bank Negara Malaysia's (BNM) AML/CFT guidelines, which were Transaction Monitoring, Record Keeping and Suspicious Transaction Reporting (STR).

Today, we will explore the training requirements as stated in BNM's guidelines on AML/CFT. Training is an important subject because all the policies and processes and procedures in the world would amount to nothing if the people in charge of executing and implementing those policies procedures and processes do not know why they are doing it and how to do it properly.

Let's take a look at the guidelines first (my paraphrase):

Section 28.6: Employee Training and Awareness Programs

RIs are required to conduct awareness and training programmes on AML/CFT practices and measures for their employees. Such training must be conducted regularly and supplemented with refresher courses.

The employees must be made aware that they may be held personally liable for any failure to observe the AML/CFT requirements.

The reporting institution must make available its AML/CFT policies and procedures for all employees and its documented AML/CFT measures must contain at least the following:

(a) the relevant documents on AML/CFT issued by Bank Negara Malaysia or relevant supervisory authorities; and

(b) the reporting institution‟s internal AML/CFT policies and procedures.

The training conducted for employees must be appropriate to their level of responsibilities in detecting ML/TF activities and the risks of ML/TF faced by reporting institutions.

Employees who deal directly with the customer shall be trained on AML/CFT prior to dealing with customers.

Training for all employees may provide a general background on ML/TF, the requirements and obligations to monitor and report suspicious transactions to the Compliance Officer and the importance of CDD. Specific Training should be held for certain groups of employees, such as: - Front-line

- Employees that establish business relationships

- Supervisors and managers

The above shows that there are quite a number of considerations to take into account when planning a bankwide training framework. As I have a personal passion in the subject matter, I will take the next few weeks to dissect the requirements and see how a simple but effective framework can be designed and implemented.

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