Top 10 Deficiencies Around the AML Training Program

Top 10 Deficiencies Around the AML Training Program

The Prevention of Money Laundering Act, 2002 and the IFSCA (AML, CFT and KYC) Guidelines, 2022 require financial institutions, DNFBPs, and virtual digital asset service providers to adequately train the staff to effectively counter ML/TF risks.

The regulated entities must design a training program and conduct training at regular intervals. The in-house AML/CFT subject matter experts or external AML/CFT training providers can conduct the training. The new employees must be immediately trained to counter ML/TF risks.

This infographic provides insights into the top ten deficiencies around the AML training program:

1. No Formal Training Program

  • – Not a part of the company’s compliance culture
  • – No seriousness regarding AML Training
  • – Improper selection of topics

2. No Evidence of Having Conducted AML/CFT Training

  • – No recording of the training conducted
  • – Improper/no record (attendance record or email RSVP) of training attendees
  • – Training material and trainer info are not kept as evidence

3. Inadequate Training on WMD Proliferation and Proliferation Financing (PF)

  • WMD Proliferation and Proliferation financing missing from training
  • – The company remains vulnerable to PF risks

4. Poor Course Content

  • – The AML training course syllabus is not up to the mark
  • – No proper legal referencing
  • – No practical insights provided as case studies aren’t made part of the training
  • – No infographics used which are easy to comprehend
  • – No engagement from participants due to poor content delivery methods

5. Knowledge Gained isn’t Tested Effectively

  • – There must be high-quality in-between and final course tests
  • – The test must cover all aspects of AML/CFT/CPF
  • – The test must have questions based on real-life scenarios
  •  – Stringent marking and feedback is necessary

6. Lack of Support from Top Management

  • – Not ready to invest in proper AML/CFT training
  • – Doesn’t scrutinise the training quality

7. Incompetent Trainer

  • – The AML Trainer isn’t CAMS/ICA certified
  • – The linking between various topics is missing
  • – Inability to convey knowledge in an engaging way

8. Post-training Guidance is Missing

  • – No proper communication with the trainer after the training ends
  • – No post-training guidance regarding the AML/CFT knowledge application

9. Not Including All the Relevant Staff Members

  • – Some employees aren’t included because management can’t see their training requirements.

10. Training Not Tailored As Per the Requirements

  • – Training doesn’t include sector-specific guidelines
  • – Generic training, not customised for the organisation
  • – Missing out on either local or global AML/CFT requirements

We are committed to assisting proper enforcement of AML and CFT regulations to regulated entities in India by designing a personalised AML framework – policies, internal controls, and procedures – and ensuring effective implementation of the same.

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