Sigma Training Academy
YOUR REGULATORY REQUIREMENTS
LATEST COMPLIANCE FAILURES
SIGMA RISK TRAINING MASTERCLASSES
Money Laundering Regulations require firms to take appropriate measures to ensure relevant staff are regularly given training in how to recognise and deal with transactions and other activities which may be related to money laundering or terrorist financing.
UK Financial Conduct Authority (FCA) has offered guidance for financial institutions on combatting financial crime. One critical example of poor practice identified by FCA during their regulatory visits at financial institutions is that training offered by some institutions being unduly focused only on legislation and regulation rather than supported by practical examples.
Your Regulatory
Obligations
AS AN ORGANISATION
Regulators around the world require supervised institutions to ensure they have robust financial crime compliance framework and one of the most critical pillar for an efficient framework is the ability of the staff members to spot, assess and manage financial crime risks arising from their client relationships. FCA Handbook Section SYSC 6.3.7 clearly outline the expectation that
“A firm should ensure that the systems and controls include appropriate training for its employees in relation to money laundering”
AS AN INDIVIDUAL
Compliance officers who fail to disclose money laundering or commit tipping off offence may be held personally accountable (possible imprisonment and/or unlimited fine) under the UK Proceed of Crime Act 2002 (POCA) and lack of knowledge or training may not be accepted as a defence in the court.
Latest Compliance Failures
In December 2022, Santander Bank was fined £107 million by the FCA. One of the key reasons identified by the FCA was a lack of bespoke training provided to the Bank’s staff members in line with their roles and responsibilities. As per the Final Notice (Section 4.89) although the staff members received external qualifications, however, they did not receive role-specific training.
Al-Rayan Bank when fined by FCA in January 2023, FCA concluded that:
“Al Rayan failed to implement sector and role specific AML training for the First and Second Lines of the business”.
Another fine in January 2023 imposed on the Guaranty Trust Bank, the FCA Final Notice. (Section 4.86) issued clearly highlights the expectations from the financial regulator. According to the FCA final notice in line with the Joint Money Laundering Steering Group (JMLSG) guidance:
“a firm’s approach to training should be built around ensuring that the content and frequency of training reflects the risk assessment of the products and services of the firm and the specific role of the individual”.
However, as per the report issued by the external consultant in November 2017, the induction AML training provided by the Bank to staff members was high-level and not tailored to GT Bank’s core products and services.
Latest Fines on AML Breaches
Al Rayan Bank, Jan 2023
National Bank of Pakistan, March 2022
Guaranty Trust Bank, Jan 2023
Gate House Bank, October 22
Santander Bank, Dec 2022
Ghana International Bank, Jun 2022
Danske Bank, Dec 2022
The Star Sydney (Casino), Oct 2022
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Why train with Sigma Risk?
Sigma Risk Masterclasses are designed by international recognised subject matter experts holding decades of practical experience in first and second line of defence departments at various global financial institutions as well as with leading international bodies including Financial Action Task Force, United Nations Office on Drugs & Crime, International Compliance Association, International Chamber of Commerce Academy and leading academic institutions.
Our training masterclasses are focused on offering real life practical experience supported through case studies, role plays, groups exercises, scenarios and interactive Q&A group discussion facilitated by our faculty. We train with the aim to equip the attendees with decision making capabilities based upon informed risk assessment with clear and structured evaluation of risk scenarios.
Our Belief
Sigma Risk believes in equal opportunities to learn for everyone. We aim to offer excellent training opportunities for organisations and individuals from around the world regardless of their jurisdiction, size of the organisation, training budgets and learning requirements.
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