Compliance Training Crucial for Belgian Financial Institutions’ AML/CFTP Effectiveness

The effectiveness of anti-money laundering (AML) and combating the financing of terrorism (CFTP) policies in Belgium’s financial institutions relies heavily on the knowledge and awareness of their staff and representatives. The AML Compliance Officer (AMLCO) plays a vital role in ensuring that staff are equipped to contribute to the implementation of these policies, but only if they receive adequate education and training.

Education as an Essential First Step

Education is an essential first step in providing staff with general information about ML/FT risks, trends, and typologies. This can be achieved through various means such as:

• Company letters
• Intranet publications
• Meetings
• Other forms of communication

However, theoretical knowledge alone is insufficient to effectively implement AML/CFTP measures.

Practical Training: The Key to Success

Practical training is necessary to ensure that staff can identify and report suspicious transactions and adhere to internal procedures. The AMLCO should provide training that covers both theoretical and practical aspects of AML/CFTP, taking into account the specific features and risk profile of each financial institution.

Proportionate Training for Each Individual or Group

The training program should be proportionate to the ML/FT risks faced by each individual or group, with a distinction made between:

• Staff working in the compliance function
• Those interacting with customers
• Those responsible for developing procedures or software

The NBB recommends that all training sessions cover key aspects such as:

• Belgian statutory and regulatory obligations
• Internal organisation
• Risk assessment
• Due diligence requirements
• Detection of atypical transactions
• Reporting of suspicions
• Recent developments in ML/FT risks

Frequency of Training

Frequency of training is also essential, with new staff receiving short-term training after entry into service and ongoing updates whenever necessary.

Monitoring Training Effectiveness

The NBB also recommends monitoring training effectiveness by:

• Verifying the understanding of AML/CFTP substance among staff
• Maintaining evidence of training sessions provided to staff concerned by ML/FT risks, agents, and distributors

Conclusion

Ultimately, compliance training is crucial for financial institutions in Belgium to prevent money laundering and terrorist financing. By providing effective education and training, AMLCOs can ensure that staff are equipped to identify and report suspicious transactions, thereby contributing to a safer and more secure financial environment.