Staff Training Obligations

Relevant Law/ Regulation: Money Laundering Regulation 21, Proceeds of Crimes Act ss 327-329, 330 (6),(7), 333, 334(2); and Terrorism Act ss 18, 21A

Training Obligations:

Relevant employees should be:

  • Made aware of the risks of money laundering, terrorist financing and bribery & corruption, the relevant legislation, and their obligations under that legislation
  • Made aware of the identity and responsibilities of the firm’s nominated officer and Money Laundering Regulations Officer ("MLRO")
  • Trained in the firm’s procedures and in how to recognise and deal with potential money laundering or terrorist financing transactions or activity
  • Staff training should be given at regular intervals, and details recorded
  • MLRO is responsible for oversight of the firm’s compliance with its requirements in respect of staff training
  • The relevant director or senior manager has overall responsibility for the establishment and maintenance of effective training arrangements