The Prevention of Money Laundering and Financing of Terrorism Regulations (PMLFTR) obliges every subject person to not only “have in place and implement measures, policies, controls, and procedures, proportionate to the nature and size of its business, which address the risks identified...”, but also to make employees aware of the measures, policies, controls and procedures established by the organization, including recording, maintenance, and updating the relevant policies on an ongoing basis to remain relevant and reflective of ongoing legislative updates.
The Scope of AML Training
The PMLFTR therefore lays down the requirement for every subject person to take timely and proportionate measures to ensure that employees are knowledgeable of relevant AML/CFT legislation and sensitive disclosure requirements, as well as of the internal AML/CFT measures, policies, controls, and procedures deployed by the organization.
It is essential for any business to factor in the required resources to train its employees, both internally and externally. The content and effectiveness of the training provided will therefore be critical to the success or failure of an organization’s regulatory and compliance framework.
A subject person should also ensure that the Money Laundering Reporting Officer (MLRO), being a senior official within the organization designated to receive and evaluate reports concerning suspicion or knowledge of ML/FT or the proceeds of crime, attends AML CFT specific training on a regular basis, in line with the Regulator’s expectations.
How can BDO Malta help?
BDO Malta can assist organizations in delivering tailor-made training to MLROs and/or key function holders overseeing the prevention of money laundering and the countering of financing of terrorism within an organization. Such training may also be provided as part of the individual’s preparation process in assuming the role.
BDO Malta may also assist with delivering tailor-made training that is aimed at providing employees of licensed entities, service providers and subject persons with an overview of their AML and regulatory obligations, such as responsible gaming and regulatory compliance in line with the licensee’s applicable regulations.