AML 12.1 AML 12.1 Training and awareness
AML 12.1.1 AML 12.1.1
Relevant Personmust(a) provide AML training to all relevant Employeesat appropriate and regular intervals;(b) ensure that its AML training enables its Employeesto:(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 Employeeis engaged and that may warrant a notification to the MLROunder AML Rule 13.2.2;(v) understand its arrangements regarding the making of a notification to the MLROunder 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 Employeesin combating money laundering, including the identity and responsibility of the Relevant Person's MLROand 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'sactivities, 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).
AML 12.1.1 Guidance1. The
DFSAconsiders it appropriate that all new relevant Employees of a Relevant Personbe given appropriate AML training as soon as reasonably practicable after commencing employment with the Relevant Person.2. Relevant Personsshould take a risk-based approach to AML training. The DFSAconsiders that AML training should be provided by a Relevant Personto each of its relevant Employeesat intervals appropriate to the role and responsibilities of the Employee. In the case of an Authorised Firmthe DFSAexpects that training should be provided to each relevant Employeeat least annually.3. The manner in which AML training is provided by a Relevant Personneed not be in a formal classroom setting, rather it may be via an online course or any other similarly appropriate manner.4. A relevant Employeewould include a member of the senior management or operational staff, any Employeewith customer contact or which handles or may handle customer monies or assets, and any other Employeewho might otherwise encounter money laundering in the business.