Compliance visit tests: Checking training and internal communications
The requirement for the internal communication of policies and procedures is in Regulation 20(1)(f). Additionally, Regulation 21 sets out the need for relevant employees to be made aware of the law relating to money laundering and terrorist financing; and for them to regularly be given training in how to recognise and deal with transactions and other activities which may be related to money laundering and terrorist financing.
The following questions should be satisfactorily answered to confirm compliance:
- Are all relevant employees and/or agents trained to carry out their responsibilities?
- Does the training cover the requirements of The MLR 2007, The POCA 2002 and The Terrorism Act 2000?
- Does the training provide adequate information on how to recognise and deal with transactions or other activity which may be related to money laundering or terrorist activity?
- Is the training kept up to date and delivered regularly?
- Are there records to demonstrate what training has been given and when?