9. A Malaysian Banking Perspective: Setting up a Training Framework
Last week we saw what are the Training requirements for banks under the BNM guidelines on AML/CFT. Today we want to spend some time looking at a basic framework that can be set up to meet the requirements.
Let me start by listing the requirements:
1. Awareness and Training Programs (Program)
2. Regularly, supplemented by refresher courses (Time factor)
3. Employees need to know potential for personal liability for non observance (Topics to cover) 4. Training to be according to their responsibilities (Audience and topics to cover)
5. Those dealing with customers must be training before dealing with customers (Time factor and Audience)
6. Training to cover general AML/CFT background, requirements/obligations to monitor transactions and report suspicious transactions to Compliance Officer and importance of CDD (Topics to cover)
7. Specific Training for Frontline, those establishing business relationships, supervisors and managers (Audience and topics to cover)
From the above we can summarise in the following parts:
1. Audience: All, Frontline and Establishing business relationships (dealing with customers), Supervisors and Managers
2. Topics to cover: Personal liability for non observance, general AML/CFT background, transaction monitoring, suspicious transaction reporting, importance of CDD, etc.
3. Time factor: Regular for new joiners and refreshers plus for those dealing with customers to be trained first prior to dealing with customers
One potential way to look at the requirements and to obtain Senior Management approval to implement a basic framework
Next week, we will look at Training Methods, i.e. how we can carry out a class to teach AML/CFT.