CHAPTER 10

TRAINING

Section 10.1. The Regulated Intermediary shall provide education and training for all its staff and personnel, including directors and officers, to ensure that they are fully aware of their personal obligations and responsibilities in combating money laundering and to be familiar with its system for reporting and investigating suspicious matters.

Section 10.2. A Regulated Intermediary may, due to the scale and nature of their operations, assign the internal audit or training functions to another person (e.g. professional association, parent company or external auditors). Where a Regulated Intermediary delegates its responsibilities for audit and training, due diligence is to be exercised to ensure that the persons appointed are able to perform these functions effectively and the fact of such appointment must be relayed in writing to the Council.

Section 10.3. Timing and content of training for various sectors of staff will need to be adapted by the Regulated Intermediary for its own needs. The following is recommended:

 i.   New Staff

A general appreciation of the background to money laundering, the need to be able to identify suspicious transactions and report such transactions to the appropriate designated point within the Regulated Intermediary.   This training shall be provided to all new employees, regardless of level of seniority.

ii.   Cashiers/Dealers' Representatives or Investment Representatives/Advisory Staff

Personnel who deal directly with the public are the first point of contact with potential money launderers. Their efforts are therefore vital to the Regulated Intermediaries' reporting system for such transactions. They should be trained to identify suspicious transactions and on the procedure to be adopted when a transaction is deemed to be suspicious. "Front-line" staff should be made aware of the Regulated Intermediary's policy for dealing with non-regular customers particularly where large cash transactions are involved, and the need for extra vigilance in cases under suspicious circumstances.

iii.   Supervisors and Managers

A higher level of instruction covering all aspects of money laundering procedures should be provided to supervisors and managers. This will include the offences and penalties arising from the Act, procedures relating to service of production and restraint orders, internal reporting procedures, and the requirements for verification of identity and the retention of records.

Section 10.4. Regulated Intermediaries shall, at least once a year, make arrangements for refresher training to remind key staff of their responsibilities and to make them aware of any changes in the laws and rules relating to money laundering,  as well as the internal procedures of the Regulated Intermediary.

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