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  • AML 12 AML 12 AML Training and Awareness

    • AML 12.1 AML 12.1 Training and awareness

      • AML 12.1.1 AML 12.1.1

        A Relevant Person must

        (a) provide AML training to all relevant Employees at appropriate and regular intervals;
        (b) ensure that its AML training enables its Employees to:
        (i) understand the relevant legislation relating to money laundering, including Federal AML legislation;
        (ii) understand its policies, procedures, systems and controls related to money laundering and any changes to these;
        (iii) recognise and deal with transactions and other activities which may be related to money laundering;
        (iv) understand the types of activity that may constitute suspicious activity in the context of the business in which an Employee is engaged and that may warrant a notification to the MLRO under AML Rule 13.2.2;
        (v) understand its arrangements regarding the making of a notification to the MLRO under AML Rule 13.2.2;
        (vi) be aware of the prevailing techniques, methods and trends in money laundering relevant to the business of the Relevant Person;
        (vii) understand the roles and responsibilities of Employees in combating money laundering, including the identity and responsibility of the Relevant Person's MLRO and deputy, where applicable; and
        (viii) understand the relevant findings, recommendations, guidance, directives, resolutions, sanctions, notices or other conclusions described in chapter 10; and
        (c) ensure that its AML training:
        (i) is appropriately tailored to the Relevant Person's activities, including its products, services, customers, distribution channels, business partners, level and complexity of its transactions; and
        (ii) indicates the different levels of money laundering risk and vulnerabilities associated with the matters in (c)(i).
        Derived from RM117/2013 [VER9/07-13]
        [Amended] DFSA RM196/2016 (Made 7th December 2016). [VER13/02-17]

        • AML 12.1.1 Guidance

          1. The DFSA considers it appropriate that all new relevant Employees of a Relevant Person be given appropriate AML training as soon as reasonably practicable after commencing employment with the Relevant Person.
          2. Relevant Persons should take a risk-based approach to AML training. The DFSA considers that AML training should be provided by a Relevant Person to each of its relevant Employees at intervals appropriate to the role and responsibilities of the Employee. In the case of an Authorised Firm the DFSA expects that training should be provided to each relevant Employee at least annually.
          3. The manner in which AML training is provided by a Relevant Person need not be in a formal classroom setting, rather it may be via an online course or any other similarly appropriate manner.
          4. A relevant Employee would include a member of the senior management or operational staff, any Employee with customer contact or which handles or may handle customer monies or assets, and any other Employee who might otherwise encounter money laundering in the business.
          Derived from RM117/2013 [VER9/07-13]
          [Amended] DFSA RM196/2016 (Made 7th December 2016). [VER13/02-17]
          [Amended] DFSA RM223/2018 (Made 18th April 2018). [VER14/07-18]
          [Amended] DFSA RM258/2019 (Made 26th June 2019). [VER16/07-19]