Ongoing Training Programs : A New Standard for Reporting Entities

Original Broadcast Date:
Wednesday, June 29th, 2011

Over the past few years, we have seen an ever-increasing standardization of AML/CTF compliance regime practices by Canada's various regulatory authorities. These standards of practice are becoming the basis on which the regulator requests information prior to an audit or examination and subsequently measures what the entity has put in place to be reported in the close-out meeting of the audit and then in the follow-up written report. This approach is becoming increasingly common in response to the growing focus of regulators on such requirements as reporting, record -keeping, policy and procedure manuals, and risk-based management practices.

Currently, reports from various sectors are referencing the focus by regulators on employee training programs and their expectation that training must extend beyond the scheduled annual event. The expectation has become that a reporting entity will have added a second level to the written ongoing training program, which addresses such topics as: when and how training takes place; the frequency of training; which employees receive the training and at what levels; method(s) of delivery; content descriptions; the differences between the annual training and the on-going training; how do you ensure retention of knowledge; how do you keep information current; to what degree of detail should the content reach; and, how do you enhance your training when new products or services are implemented?

The annual training process by itself is absolutely required but no longer sufficient to meet the current training standard of practice. Compliance officers and company executives can no longer be satisfied with this annual event. Training to be effective must be dynamic in nature to ensure it is current; reinforced to ensure retention; reviewed to maintain consistency; and a regular element of the working life of each employee and manager. Failing to do so could put the corporate compliance regime at risk for not meeting the standards of practice that are needed to ensure all employees and managers are "on top of things".

Drawing on his wealth of experience in AML/CTF training and education, Chris Walker of About Business Crime Solutions discusses the new level of training footprint compliance officers need to put in place to meet this key pillar in the legislated AML Compliance Regime

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