So here’s the thing. If you work in a large organisation, say a Bank, Insurance provider or Oil and Gas Company you are going to be deluged with training. When you join and at regular periods you will experience “death by CBT” (Computer Based Training). You know the score, online courses that involve clicking through a series of slides to a brief multiple choice (or multiple guess as it’s often called!) test. Job done, box ticked and you can get on with your life.
I know of one large financial services firm, where on joining you must complete 10 CBT courses within a week: Anti Money Laundering, Data Security, Health and Safety, Anti-Bribery and Corruption, Compliance, Ethics, IT Policy, Treating the Customer Fairly, Sanctions and Whistle blowing. Is this overkill?
Well as they say “the times they are a changing”!
Increased regulatory expectations, rising standards and best practice now makes it clear that clicking through a CBT course does not mean people have been given the right skills to tackle the complex issues facing regulated firms today.
Listen, CBT is not a bad thing, in fact if you are in an organisation that employs hundreds or thousands of staff across multiple locations, it's essential to ensure you reach people in a cost effective and efficient way. However CBT is only ever going to be a baseline. There will always be people who by virtue of their roles need more specialised skills and training to support them.
We have seen failings and huge fines in large institutions for AML, ABC and Compliance issues where staff fail to think critically and put issues into the bigger context. What this means is that the expected standard has been raised when it comes to training and awareness. Regulators around the world increasingly expect to see evidence of an effective and risk based approach to training and awareness.
So what is best practice in training for AML and Compliance?
1. A risked based training and awareness strategy that is endorsed by Senior Management (i.e. get a plan approved at a board meeting). What are the higher risks or more complex roles in your organisation? What specific training and skills do these roles require? How will you evidence this?
2. Customise training. It is not appropriate to provide account opening or client on boarding staff with generic training focussing purely on the law and regulation. In the current regulatory climate they need meaningful case studies and examples relevant to their roles. The key is to develop critical thought and application of the law and regulation to real life scenarios. In turn, don’t forget senior management, tailor a briefing session for them with the key issues in terms of the commercial benefits of AML and Compliance and in particular the impacts on share price!
3. A tiered approach to training. Offer a clear progression for staff. From basic awareness courses, to intermediate qualifications through to advanced and masterclass level sessions for Compliance and AML practitioners. Taking an overall view of the “learning journey” will motivate your staff in terms of career progression and demonstrate a real commitment to their personal development from their employer. Remember regulators expect firms to demonstrate the competency of their AML and Compliance staff as well.
4. Certification. How credible is your training? Is there independent certification on the learning outcomes? Has the learning been evidenced through examination? Can you satisfy your senior management, auditors and regulators that it is effective?
5. Give it the wow factor! Keep training engaging for staff. Use interesting and “sexy” case studies. Use different media, face to face sessions, newsletters, desk drops and put the issues in context for staff in terms of how it relates to them and their jobs. Don’t forget to motivate and energise your people as to why AML, ABC and Compliance really matters.