How to start internal training on AML and combating the financing of terrorism

Training is a crucial part of every organisation's efforts to combat money laundering and terrorist financing.

In this article, we take a closer look at how targeted training enables your employees to recognise and respond to suspicious activities.

We cover the key questions: who, what, where, when and why – and provide you with a roadmap to help ensure that your organisation's training programme is structured and becomes an active and positive part of your compliance programme.

What is the purpose of the training?

The purpose is to enable employees to recognise attempts at money laundering or terrorist financing.

Through targeted training and practical examples, employees should be able to identify and detect changes in the business relationship surrounding the client.

This may, for example, include unjustified changes in ownership structure, business activities or the type of advice requested from the organisation. In addition, there should be a clear link between the training and the work tasks arising from the anti-money laundering rules, such as carrying out customer due diligence procedures.

It is therefore not sufficient for the training to consist solely of a review of the provisions of the Anti-Money Laundering Act.

The rules also require that the training includes the processing of personal data, which may, for example, build on the organisation's GDPR training programme.

Why is it important?

Employees must be able to respond to circumstances that appear unclear or unusual, enabling the organisation to comply with the requirements of the Anti-Money Laundering Act.

Training therefore acts as a safeguard against the organisation being misused for money laundering, which may have both financial and reputational consequences.

Who should receive the training?

All employees who work with client relationships – including management. The training can be tailored to suit the specific job functions carried out by the employees concerned.

Where should the training take place?

The most important factor is that the training is tailored to the organisation's profile and business activities. This provides flexibility to design the training using different approaches, such as in-person meetings, online courses, awareness campaigns focusing on anti-money laundering topics, and targeted AML training sessions for relevant departments using practical examples.

When should you plan the training?

Training should take place at appropriate intervals, taking into account your Section 7 risk assessment. This follows the principle that departments handling high-risk clients should receive training more frequently than departments with lower-risk clients. If the organisation's internal procedures are updated, the relevant employees must also receive refresher training.

How should you approach it?

An annual compliance calendar can help ensure that training takes place at appropriate intervals, that new employees receive training as part of their onboarding, and that documentation is maintained to demonstrate that the training has been completed and that the relevant employees have participated.

What are the next steps?

Are you preparing to update your organisation's AML training programme? If so, here is a suggested roadmap:

1. Are roles and responsibilities in place?

• • Which member of management has overall responsibility for the training?

  • Who has operational responsibility for ensuring that the training programme is carried out?

  • Who has the authority to make the training mandatory and enforce participation?

2. Do we have an annual compliance calendar describing the initiatives we have chosen to include in our training programme?

3. Do we have the necessary documentation in place so that, for example, we can provide evidence of participation during a supervisory inspection?

Well-planned anti-money laundering training is not only a regulatory requirement, but also an investment in your organisation's security and integrity. By providing employees with ongoing and targeted training, you create a strong first line of defence against money laundering and terrorist financing. Start updating your training programme today and ensure that your organisation is well prepared for the compliance challenges of the future.

Note: The article is an excerpt from our e-book "Rejsen Gennem Hvidvaskloven", written in collaboration between Kristine Sorken and Creditro. The e-book provides a practical overview of the requirements of the AML legislation, together with actionable guidance for your compliance work. You can download the full e-book here (Danish only).