14.1.1. Training and Other Obligations

A Relevant Person must implement screening procedures to ensure high standards when hiring employees.

A Relevant Person must take appropriate measures to ensure that its employees:

1. (a) are made aware of the law relating to money laundering;
2. (b) are regularly given training in how to recognise and deal with transactions and other activities which may be related to money laundering;
3. (c) understand its policies, procedures, systems and controls related to money laundering and any changes to these;
4. (d) understand the types of activity that may constitute suspicious activity in the context of the business in which an employee is engaged and that may warrant a notification to the MLRO under AML 13.7.3;
5. (e) understand its arrangements regarding the making of a notification to the MLRO under AML 13.7.3;
6. (f) are aware of the prevailing techniques, methods and trends in money laundering relevant to the business of the Relevant Person;
7. (g) understand the risk of tipping-off and how to avoid informing a customer or potential customer that it is or may be the subject of a STR;
8. (h) understand the roles and responsibilities of employees in combating money laundering, including the identity and responsibility of the Relevant Person’s MLRO and deputy, where applicable; and
9. (i) understand the relevant findings, recommendations, guidance, directives, resolutions, sanctions, notices or other conclusions described in Chapter 13.

14.1.2. Appropriate measures

In determining what measures are appropriate under AML 14.1.1 Relevant Person must take account of:

1. (a) the nature of its business;
2. (b) its size; and
3. (c) the nature and extent of the risks of money laundering to which its business is subject. The AFSA may impose additional training requirements in respect of all, or certain, relevant employees of a Relevant Person.

Guidance on training and awareness

1. (a) All relevant employees of a Relevant Person be given appropriate AML training as soon as reasonably practicable after commencing employment with the Relevant Person. A relevant employee means a member of the senior management or operational staff, any employee with customer contact, or any employee who handles (or may handle) customer monies or assets, and any other employee who might encounter money laundering in the business.
2. (b) Relevant Persons should take a RBA to AML training. AML training should be provided by a Relevant Person to each of its relevant employees at intervals appropriate to the role and responsibilities of the employee. In the case of an Authorised Firm, training should be provided to each relevant employee at least annually.
3. (c) AML training provided by a Relevant Person need not be in a formal classroom setting, rather it may be via an online course or any other similarly formal and documented manner.