It's the first day of summer and of course it is pouring with rain and blowing a gale whilst I try to compose a few pertinent words about training. When I talk of training of course I am referring to my own area of expertise which is anti money laundering and kindred issues.
I have spent a little while over the past few days creating the outline of one day AML course that I can present through a local training provider, and it occurred to me that there is an awful lot of content that could be included. Is it all necessary though? Yes, of course if you are in a specific profession then there will be specific issues that relate to you, but only to you and that is the problem with AML training generally, it can be too detailed. When I look around I see that there is bespoke training available for lawyers, accountants, banks, and other financial services providers, but I don't see anything that is really general in nature. By general I mean something relatively short and concise that would be appropriate for the great number of ordinary businesses out there who merely want to comply with the law and ensure that criminals cannot take advantage of them by laundering their ill-gotten gains through them.
Training is provided in some Metropolitan areas but at what cost? One example I found was for 3 hours training for £299 per person, and that is something that small and medium sized businesses usually cannot afford, and if they could, many would be loathe to spend that type of money on what is considered to be a niche area. When you consider that all members of staff regardless of their position have a role to play in making sure the reputation of the business is protected and the threat to it is minimised, you want to encourage as many people as possible to attend at an affordable price.
This can be achieved by cutting out a lot of the more specialised areas that are specific to only a few professions as they can be delivered to those people on a needs basis. All that business in general needs to understand in the first instance is:
I have spent a little while over the past few days creating the outline of one day AML course that I can present through a local training provider, and it occurred to me that there is an awful lot of content that could be included. Is it all necessary though? Yes, of course if you are in a specific profession then there will be specific issues that relate to you, but only to you and that is the problem with AML training generally, it can be too detailed. When I look around I see that there is bespoke training available for lawyers, accountants, banks, and other financial services providers, but I don't see anything that is really general in nature. By general I mean something relatively short and concise that would be appropriate for the great number of ordinary businesses out there who merely want to comply with the law and ensure that criminals cannot take advantage of them by laundering their ill-gotten gains through them.
Training is provided in some Metropolitan areas but at what cost? One example I found was for 3 hours training for £299 per person, and that is something that small and medium sized businesses usually cannot afford, and if they could, many would be loathe to spend that type of money on what is considered to be a niche area. When you consider that all members of staff regardless of their position have a role to play in making sure the reputation of the business is protected and the threat to it is minimised, you want to encourage as many people as possible to attend at an affordable price.
This can be achieved by cutting out a lot of the more specialised areas that are specific to only a few professions as they can be delivered to those people on a needs basis. All that business in general needs to understand in the first instance is:
- The three stages of money laundering, the history of its development, why it is important, and the consequences of non-compliance.
- The legal framework of the relevant UK legislation dealing with money laundering and the proceeds of crime, and how to comply.
- What is meant by the Risk-Based Approach and how to conduct a risk assessment in the workplace.
- The main principles of Know Your Customer or Customer Due Diligence.
- The meaning of suspicion and how to recognise and report it.
- High Value Dealers and other high risk businesses.
This is a good first module and if people are interested in improving their understanding or want material that is specific to their business that can be designed too. I think for far too long the mystique around money laundering and the countering of terrorism has been allowed to develop to the extent that people view it as a complicated and specialised subject, trained by the few, at rates they think they can achieve. It doesn't need to be, and my view is it should be shared with as wider an audience as possible because it is only through raising awareness at grassroots level generally that it will be tackled successfully.
If you have any comments I will be pleased to hear them.
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