AML training must be more than mere lip service


In a recent sanction by the Central Bank, attention is being drawn to the fact that anti-money laundering (AML) training needs to be focused, specific and ongoing. In the sanction report, a financial services firm was fined €443,000 in June 2018 for failures that included lack of appropriate AML training.

The sanctions report reads: ‘it had inadequate policies and procedures to monitor transactions, detect and report money laundering and provide its staff with appropriate training’.

In addition, the Central Bank found that the company:

  • failed in many areas to provide the appropriate amount, level, and accuracy of training for its staff;
  • training was not focused on the specific roles and responsibilities of staff (especially at Money Laundering Reporting Officer (MLRO) level;
  • training did not amount to a sufficient amount of time to train them on how to identify suspicious activity;
  • the entity failed to provide training to all client facing staff; and
  • there was a failure to ensure staff were instructed on AML and counter financing of terrorism (CFT)-related law, and a failure to provide ongoing training.

From 15 July 2010 to 10 September 2012, the firm breached section 54(6) of the Criminal Justice (Money Laundering and Terrorist Financing) Act, 2010, because it failed to train anyone involved in the conduct of its business in AML/CFT law or provide on-going instruction on identifying suspicious activity.

Over a three-year period, the firm had held one-hour annual AML/CFT training session for staff. The Central Bank stated the ‘training was sufficient to introduce staff to AML/CFT law but in further breach of section 54(6), it was insufficient to train them to identify suspicious activity. In addition, the scope of the training was not tailored to specific roles, including the Firm’s MLRO’.

To hear more about the AML requirements that must be applied by accounting firms, including a suggested spreadsheet to control all the main topics, come to our next AML seminar on Tuesday 25 September 2018 at the Talbot Hotel Stillorgan, County Dublin.

Booking is here via our website. Cost is €105 per delegate or €280 for three delegates from the same office.