AML Training Requirements
1. Purpose
This policy (Ref: COMP-AML-005) establishes the Bank's mandatory Anti-Money Laundering training requirements for all staff. Effective training is a regulatory obligation under AMLD6, FATF Recommendation 18, and FCA guidance (FC16/8). It ensures that employees can identify, prevent, and report suspicious activity.
2. Scope
This policy applies to all permanent employees, temporary staff, contractors with access to customer data or transaction systems, and Board members. Third-party agents acting on behalf of the Bank must demonstrate equivalent training standards.
3. Training Programme Structure
3.1 Induction Training
All new joiners must complete the AML Foundations e-learning module within ten (10) business days of their start date. Access to customer-facing systems will not be granted until induction training is marked as complete in the Learning Management System (LMS).
3.2 Annual Refresher Training
All employees must complete annual AML refresher training by 31 March each year. The refresher covers regulatory updates, emerging typologies, and case studies relevant to the Bank's operations.
3.3 Role-Specific Training
In addition to the general programme, employees in higher-risk functions must complete role-specific modules:
| Role / Function | Additional Training Module | Frequency |
|---|---|---|
| Relationship Managers | CDD and EDD in Practice | Annually |
| AML Unit Analysts | Advanced Transaction Monitoring and Investigation Techniques | Annually |
| Trade Finance Staff | Trade-Based Money Laundering Red Flags | Annually |
| Private Banking / Wealth Management | High-Risk Client Management and PEP Handling | Annually |
| Correspondent Banking | Correspondent Banking AML Risks | Annually |
| Senior Management / Board | AML Governance and Accountability | Annually |
| IT and Operations | Sanctions Screening Systems and Data Quality | Bi-annually |
4. Training Content
All AML training modules must cover, at a minimum, the following topics:
- The Bank's AML policy framework and key policies (COMP-AML-001 through COMP-AML-004).
- Legal obligations and criminal liability for failure to report suspicion.
- Red flags and indicators of money laundering and terrorist financing.
- The SAR reporting process (internal and external).
- Tipping-off prohibitions.
- Sanctions obligations and screening procedures.
- Recent enforcement actions, case studies, and regulatory developments.
5. Delivery Methods
Training is delivered through a combination of:
- E-learning modules — Hosted on the Bank's LMS, with automated tracking and certification.
- Instructor-led sessions — Delivered by the Compliance Department or external subject-matter experts for role-specific and advanced modules.
- Case study workshops — Scenario-based exercises facilitated by the AML Unit.
- Regulatory briefings — Ad-hoc communications issued by the Compliance Department in response to significant regulatory changes or enforcement actions.
6. Compliance Tracking and Escalation
Training completion is tracked via the LMS. The following escalation process applies for non-completion:
| Overdue Period | Action |
|---|---|
| 1–14 days overdue | Automated reminder to employee and line manager |
| 15–30 days overdue | Escalation to department head; access restrictions may be applied |
| 31+ days overdue | Escalation to Head of Compliance; formal non-compliance record; potential restriction from client-facing duties |
Completion rates are reported to the Board Compliance Committee on a quarterly basis. The Bank targets a minimum completion rate of 95% across all mandatory modules.
7. Assessment
Each e-learning module includes a knowledge assessment. Employees must achieve a minimum score of 80% to pass. Employees who do not pass on the first attempt must retake the assessment within five (5) business days.
8. Review
This policy is reviewed annually by the Compliance Department. Next review: Q1 2027.