Business regulated by or registered with the Alderney Gambling Control Commission (AGCC), the Guernsey Financial Services Commission (GFSC) and the Jersey Financial Services Commission (JFSC) have requirements under the relevant AML/CFT (Anti Money Laundering and Combating the Financing of Terrorism) handbooks or guidelines to ensure regular ongoing training for their staff in this area.
The requirement to train staff in this area is not new, however often training is carried out in these areas alone, and is directed if not carried out by the Money Laundering Reporting Officer (MLRO). How many times have experienced practitioners been forced to take time out from their working day to sit through an hour-long in-house seminar and are able to repeat “placement – layering – integration” or “maximum of 14 years in prison and an unlimited fine” verbatim at their course leader simply from hearing it so many times. Also, how many people have been forced to watch an AML DVD with dodgy acting from Z-list actors portraying farcical characters?
Running in-house training sessions during lunch breaks inevitably leads to:
- Running multiple training sessions, taking up the valuable time of the MLRO
- Running additional training sessions for those who are unexpected unable to attend at the last minute (sickness or business)
- New staff members joining the company who need to have the training provided as part of their induction, which will often be at a time when regular staff training is not scheduled
- Knowing that someone has been physically present without being able to prove that they were mentally present
- Lack of quantitative proof of the effectiveness of the training
Clearly, this is not the best solution to a regulatory training need.
Convenience and Scalability
In the modern era we often talk about flexibility, and this is now something that can be offered in the ongoing training space. Let’s take an example.
Company A decides that its employees need to complete their regular AML/CFT training in line with regulatory requirements. The company has engaged with an online training provider (who happen to be called Midshore) to use their online training solution. Taking the experiences of various executives of the company:
- The Managing Director decides to login from his tablet at home one evening to complete the training – leading by example is important
- The Sales Director has a rare few days in the office so decides he will complete it one lunchtime whilst eating a sandwich at his desk
- The Operations Manager doesn’t have enough time during the working day so takes her mobile phone to the gym, logs into their Wi-Fi and burns calories on the cross-trainer at the same time
- The MLRO and the Human Resources Manager receive regular reports on who has completed the training, together with the score that each employee has received for their end of course test
Midshore Online Training (MOT)
Midshore Online Training (MOT) is the online training solution brought to you by Midshore Consulting. Regularly updated, the Midshore AML/CFT training includes sections on Proliferation Financing, Sanctions and Anti-Bribery and Corruption (ABC) alongside the standard AML/CFT subject matter.
The training module consists of:
- Online training video
- Printable course notes
- 15-question end of module test (75% pass mark)
- Printable certificate of completion
Using MOT also means that staff located in other jurisdictions (including those in outsourced or offshored operations) can receive identical training to local staff.
MOT – more than AML/CFT
Regulation and legal requirements are changing all the time, additionally local businesses are not just impacted by local law and regulation. Staff in regulated businesses should receive more than just AML/CFT training on a regular basis to ensure that they remain aware of their responsibilities in a number of key areas. This is why the MOT suite of modules will also include:
- Data Protection Awareness
- FATCA/CRS Awareness
- Information & Cyber Security
- Guernsey Pension Regime
- Client Money & Client Assets
- AIFMD for Third Country Firms
- MiFID II & MiFIR for Third Country Firms
At this point, it almost seemed appropriate to include a pun about booking staff in for a MOT! However, should you be interested in a scalable and cost-effective solution to ensuring your staff have up to date regulatory knowledge please contact us.
Midshore can also run in-house training, including practical workshops tailored to the needs of your business.