AML-CFT Awareness Training
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 the recording, maintenance, and update of the relevant policies on an ongoing basis to remain relevant and reflective of ongoing legislative updates.
The PMLFTR 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. This, therefore, entails the provision of AML/CFT and industry specific training in relation to the recognition and handling of operations and transactions that may be related to proceeds of criminal activity, money laundering or the funding of terrorism.
Providing awareness and training in relation to the AML/CFT procedures and training in relation to identification of unusual activities or suspicious transactions are key elements in the detection and deterrence of ML/FT activities. It is, therefore, essential for business development to factor in the required resources to train its employees, both internally and externally.
The best designed AML/CFT policies and procedures remain ineffective should they not be enforced company-wide by employees. The content and effectiveness of the training provided will therefore be critical to the success or failure of an organization’s AML-CFT framework.
BDO Malta can assist with providing tailor-made AML/CFT training that is aimed at providing employees of licensed entities, service providers and subject persons with an overview of their AML and CFT obligations, in view of having the ability to execute transactions on behalf of the organization, and, therefore, act as front figures in the identification of unusual transactions, and riskier situations that may turn out to be suspicious.
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