Your firm is being supervised on three main aspects. Firstly this is implementing policy and procedures for AML purposes helping mitigate risk. In particular that ‘actions you take are consummate to the risk assessed’. Therefore your firm will have introduced policies and procedures for which you are accountable for as part of your job description. This will include client due diligence measures and record keeping requirements.
Secondly your nominated officer will set up systems for reporting ‘suspicious activity’ both internally and externally. For example, who to report to and how do you make that report?
Compliance is an integral part of your role within your organisation. Your employers final aspect of their compliance is the training of staff. Your employer will train you accordingly when you first start with the firm and then continue to update your training at regular and appropriate intervals concerning;-
- Awareness of obligations under the AML Regime
- Education on Client Due Diligence and the risk based approach
- Ensuring a culture of vigilance
- Ensuring you are aware of the firm’s policy and procedures
- How to report and who to
- On how to spot suspicious events or transactions
- Updating you with developments and updates to the Regulations
- Client acceptance and account opening procedures, and
- Making you aware of the laws relating to money laundering and terrorist financing
Your firm will have introduced policies and procedures, the MLRO will have implemented procedures for reporting suspicious activities, and finally your firm will be investing in training for you. This is possibly why you are undertaking this online training course.
The Supervisor has the right to ‘test’ the requirements of you firm, one way of testing systems is to question employees about their understanding of not only the firms’ implemented procedures but also their understanding of the legislation and offences of money laundering.