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New Employees Must Be Trained on Money Laundering Reporting
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In a bid to prevent money laundering and terrorist financing, new employees at financial institutions must be trained on the importance of reporting suspicious transactions.
Guidelines for Training
According to guidelines issued by the Financial Intelligence Unit (FIU), all new employees who will be dealing with customers or their transactions, regardless of their level of seniority, must receive training within the first month of employment. The training will cover:
- The background to money laundering
- The need for reporting suspicions
- The legal requirements for doing so
Emphasis on Awareness among Front-Line Staff
The guidelines also emphasize the importance of awareness among front-line staff, such as:
- Cashiers
- Foreign exchange operators
- Advisory staff
These staff members should be trained on factors that may give rise to suspicion and procedures to adopt when a transaction is deemed suspicious.
Account Opening Personnel Training
Account opening personnel must receive training on:
- Verifying customer identity
- Reporting suspicious transactions
Supervisors and Managers Training
Supervisors and managers must have a higher level of instruction covering all aspects of money laundering procedures.
Refresher Training
The FIU has also emphasized the need for refresher training for all staff at least annually to ensure they do not forget their responsibilities and keep abreast of new developments in anti-money laundering measures.
Protection of Reporting Persons and Staff
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The guidelines also provide protection for reporting persons and staff from criminal and civil liability if they report their suspicions in good faith, even if they did not know precisely what the underlying criminal activity was.
Prohibition on Tipping Off
Banking institutions, directors, officers, and employees are prohibited from disclosing to customers that a suspicious transaction report or related information is being reported to the FIU.
Effective Date and Feedback
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The guidelines will become effective on April 1, 2009. Financial institutions are encouraged to compile and record any comments they may have relative to these guidelines and forward them to the FIU for its appropriate action.
Examples of Suspicious Transactions
The FIU has provided examples of suspicious transactions that may indicate money laundering activities, including:
- Unusually large cash deposits made by an individual or company whose ostensible business activities would normally be generated by cheques and other instruments.
- Substantial increases in cash deposits without apparent cause, especially if such deposits are subsequently transferred within a short period out of the account and/or to a destination not normally associated with the customer.
- Customers who constantly pay-in or deposit cash to cover requests for bankers drafts, money transfers, or other negotiable and readily marketable money instruments.
Conclusion
The guidelines aim to prevent money laundering activities by ensuring that all financial institutions are aware of their responsibilities in reporting suspicious transactions.