Undertaking regular Anti Money Laundering (AML) training, at least once a year, is a key part of your obligations under the Money Laundering Regulations 2007, but we find that this requirement to give ongoing training can be over-looked.
Practices are required to ensure that all relevant employees are ‘made aware’ of law relating to money laundering and terrorist financing, and then regularly given training. In an insolvency practice that would cover all those who are involved with the administration of insolvency cases, together with the office holder. The ongoing training should focus on how to recognise and deal with transactions which may be related to money laundering or terrorist financing. Given the various offences under the Regulations that an office holder, or indeed an employee, can commit, then providing employees with reminders on the law relating to money laundering and terrorist financing and on the practice’s AML procedures should not be over-looked as a good way of helping to protect the practice.
Finally, don’t forget that any new employees in the practice need to receive some initial training on the practice’s AML procedures. They will also need some training on the law relating to money laundering and terrorist financing unless you are certain that they have already received some, say at another practice. If you are relying on prior training you should have evidence of the training provided and that it at least meets your standards.
