Annual Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) Training

Wed Jul 22 2020

Brokers Ireland Template Presentation 2020: Annual Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) Training

As you are aware it is a requirement for all financial services firms to provide annual Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) training to their staff. This training must be appropriate and sufficient and tailored to the firm, and reflect the firm’s AML/CFT policies and procedures.

Brokers Ireland Template Presentation

Brokers Ireland template presentation has been updated and is available in the Compliance Support section of our website under the Anti-Money Laundering heading. The purpose of the template is to provide a format for staff training which can be used by members, but must first be personalised to include reference to the firm’s specific AML/CTF procedures and processes.

Continuous Professional Development (CPD)

Brokers Ireland’s would, in the past, have sought two hours CPD accreditation from the LIA, III and IOB. This year, Brokers Ireland is unable to seek accreditation on behalf of members. The presentation needs to be presented by a Qualified/Grandfathered individual within the firm. Brokers Ireland are unable to seek accreditation for members for the template presentation 2020 as we cannot verify that the trainers are qualified/grandfathered. Therefore, each firm who wishes to use the BI presentation (for the purposes of fulfilling CPD requirements) must first personalise it and seek accreditation from their respective educational bodies; LIA, III and IOB, themselves.

Firms who wish not to seek CPD accreditation may still use the presentation to fulfil their annual requirement but must also personalise it to ensure that it reflects the firm’s AML/CFT policies and procedures.

The LIA and the Insurance Institute of Ireland have stipulated that a soletrader cannot avail of the CPD as there must be active participation in the presentation. i.e. one cannot read the template and get formal hours.

Annual Training and Assessments

Members should note, all Partners/Directors including non-executive directors are required to undertake AML/CFT training as well as all staff.

Also, as you are aware firms should ensure that the AML/CFT training provided includes an assessment or examination during the training session which needs to be passed in order to be recorded as complete. If the training does not contain an assessment or examination, firms must be in a position to demonstrate effectiveness of the training and staff understanding in relation to same.

Receiving a CPD cert is not dependent on a staff member passing the assessment. Once they have attended the training in full, they are entitled to the cert. However, for the training to be recorded as complete (from an annual requirement perspective) they must pass the assessment.

Member firms can access the template presentation 2020 in the presentations folder in Anti-Money Laundering and Counter Financing of Terrorism section in Compliance Support of the members’ area of the Brokers Ireland website. Brokers Ireland have also produced a Q&A which can be used following the presentation to test attendees’ knowledge. However, we suggest members could substitute some of these questions with their own.

You must keep a record of the date of training, the type of AML/CFT training provided, and the names of individuals who attended and whether they passed the assessment/test.

General Insurance

General insurance brokers are outside the scope of the AML/CFT legislation. However, they are expected to be mindful of other legislation that would apply such as Financial Sanctions, and to have controls and procedures in place to detect and prevent financial crime, and as a result, to report knowledge or suspicions of money laundering transactions. Staff would need to be trained also in this regard. Brokers Ireland would suggest that you personalise the presentation to suit your needs and seek accreditation from your respective educational body/bodies.

If you have any issues with any compliance matter please email Brokers Ireland at compliance@brokersireland.ie