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3 Signs of an Effective AML Course

More and more businesses are catching on to the importance of anti-money laundering (AML) training. However, as you hear or read the latest regulatory actions against various financial institutions, you will almost always see lack of training listed in the deficiencies section of the action. With proper AML training, both individuals and large institutions, who satisfy their regulatory obligations and more importantly who rise up to meet those obligations may actually help prevent crimes as serious as terrorism, human trafficking, illegal narcotics, etc from happening. AML training is a bit of a grey area as there are no hard and fast rules about the type of training, quality of training. or length of training required. One institution I reviewed believed that a 20 minute YouTube video once a year was sufficient. They were obviously concerned about their budget, the cost of the training, and the cost of manpower being away from their desks. They felt a cheap video was a wiser budgeting decision than an investment in the protection of the public and their company. They did not give adequate consideration to the potential of, or the possibility of, various types of risks or even worse, perhaps they did…but they just didn’t care.

Unfortunately, I can’t definitively say what is an acceptable amount of time to dedicate to AML training. This will depend on numerous factors such as the size of your institution, the products sold or used, the risk appetite, and the level of regulatory actions concerning a particular institution. While a basic knowledge about money laundering is helpful, it isn’t enough. Money laundering by nature is complicated and therefore requires a thorough AML training course(s) to fully grasp the subject. However, not all training courses are created equally.  Three suggestions for an effective AML course are: Experienced Teacher, Content and Delivery Methods.

An Experienced Teacher

These days, just about anyone can create an online course. However, that doesn’t mean that they have the expertise to properly construct the curriculum and convey the material. Many courses are built and presented by self educated creators. While it’s great to self educate by reading articles and textbooks about money laundering it does not make a qualified instructor. In order to adequately and thoroughly teach any subject, it is essential for an instructor to support their knowledge gained from a book with the experience of real life application. Would you consider getting corrective eye surgery from a ‘technician’ who received their training by listening to an instructor parrot information they read in a book? Of course not. Companies must also entrust employees to be qualified to act on behalf of the company and to be qualified employees need quality AML training. It’s best to choose a course(s) taught by a teacher that has actively worked in the AML industry. So, always, always, do your due diligence on the bio of the person teaching the course.

Content

This may be a no-brainer, but the content of any education determines whether or not it’s effective.  A course can have a phenomenal teacher but if it’s lacking material it may be a waste of time. Content should address attendees’ level of training needs, roles in the company, provide real world content that’s applicable to the specific industry, etc. A good course plush with meaningful material should have wow moments that make light bulbs go off over your head like fireworks. At some point you should be saying things to yourself like, “Wow, I never knew that,”, “Wow, I needed to know that,” “Wow, that’s going to help me do my job better.”  What is most important to note is that training is about the student actually learning. It should not be about a check the box and please the regulator approach. While the regulators, ultimately do need to give approval, your approach should be to provide training that would no doubt be approved by regulators, law enforcement, your companies’ commitment to excellence, and your customer. Doing just enough to slide by and appease the regulators is lame, lazy and downright dangerous.

Teaching is also not about the instructor looking good wearing a million dollar suit, (although there’s nothing wrong with that as long as there’s more than just a nice suit) sounding impressive with 5 syllable words and/or name dropping of all the head honcho’s. If the instructor is not putting the attendees first he may be distancing himself from the attendees and missing the mark on the course material. These types of sessions often turn into a lecture from some empty suit who shows little connection with the attendees and therefore the attendees may tune that instructor out.

Instructors should know some of the basic rules of Powerpoint if that is something they use. A miserable Powerpoint tells me something immediately – the instructor (or designer) did not care enough about the attendees to put appropriate effort into providing a more visually appealing and easier to understand presentation.  Whenever I see a Powerpoint that looks like someone cut and pasted notes onto a slide and it reads like a paperback novel, I immediately say one thing – lame. Ultimately the program needs to have the proper content, needs to be engaging and understandable, must be delivered with an “I’m one of you” attitude, and the course material should be well organized and visually engaging. This style of teaching goes a lot further towards the information being accepted by the staff, remembered by the staff, and ultimately implemented by the staff. An instructor needs to remember, it’s not about them. It is about the amount of knowledge being transferred to the attendees. Are they learning? Are they walking out of the classroom retaining and repeating information that was presented? Are they utilizing what they learned when they return to work? If the instructor can accomplish these things then you have the framework of a quality training course that yields high return on your training investment.  

Delivery Methods

We all know that training gets the last bite of the budget apple which usually means the quality of the training and the delivery system are as low as the budget. With limited resources the overall training could rank anywhere from acceptable, to lame, to pittyfull, to potentially putting your institution at risk and downright disgraceful.  I’ve seen some institutions that give it their best in spite of the bad hand they have been dealt, and I’ve seen others throw in the towel. Let’s briefly discuss training delivery methods.

The two main delivery methods are: 

  1. Online training, including video conferencing, live webinar style, and on demand e-training, to name a few and; 
  2. On-site training.

Additionally, the training room itself and its impact on delivering the message deserves consideration.  We’ll talk about this later.  

Common shortcomings of many online training courses.

  • Boring and not engaging.  If attendees are lulled into a coma by boredom in the first 5 minutes and then zone out, what good is it? If the material isn’t engaging and attendees forget the content the moment the training ends, what good is it? Training should be interactive and tell a real world story that is exciting and applicable.  
  • Multi-tasking.  When at your desk, doing the on-line course, it is far too tempting to multi-task. Checking your e-mail, checking phone messages, answering the phone, finishing up some paperwork, reading the newspaper, or just not paying attention are all risks of online training programs. The nature of online training can allow for many distractions and there is no one there to command attention and keep the attendee focused. Online training courses should engage attendees and require periodic feedback to prevent the student from zoning out.  Further, there should be a graded quiz after the training to review the material, confirm understanding of the material, and to indicate to the regulator that the staff did take the course and passed an assessment to complete the training.
  • Institutions’ who train to satisfy the regulators instead of training employees to understand the topic.
  • The unfortunate technical issue that can drive attendees nuts.  
  • Employees leaving the course in their queue and then having to zip through it at the last moment
  • No place to network and/or ask real questions of other students and/or the instructor
  • Course content that leaves much to be desired.

Now, on to the positive side of online training which has some very significant benefits.  

  • Cost effective
  • Ability to train employees from multiple locations at the same time.
  • Little issues with scheduling.
  • Live webinar training may allow for interaction with the instructor

Shortcomings of live webinars and onsite training:

  • Logistics – getting everyone in the same room at the same time
    • Who’s steering the ship while everyone is attending the training course?  Are multiple training dates required?
    • Cost to have attendees come to one location or the cost of sending instructors to various locations for onsite training.

Benefits of live in-person training:

  • Face to face allows a good instructor to be more engaging and connect with the attendees.
  • Content may be specifically tailored for the attendees.  Further, a good instructor while teaching, identifies areas attendees are struggling with and provides additional focus on that material while also identifying areas they are missing information and adjusts the course content to address those needs.
  • Discussion – human interaction.  It is much easier to facilitate interaction and converse with others onsite or in small live webinar classes. This provides attendees with several valuable benefits: question/answer sessions, follow up discussions, feedback, group activities, etc. Engaged students have increased retention and understanding of the material.
  • One to one with the instructor. Before class, during class, while on breaks, lunchtime or after class. There are plenty of moments to speak to the instructor.  Even if it is only indirectly related to the topics attendees often receive helpful pointers in these brief conversations. A moment with the instructor may get an answer to a topic or an event that one of your employees is currently addressing.  You or other students may ask questions that you might not be able to ask during an e-training course. Further, you may hear how other co-workers are doing things and it might spark some new thoughts and solutions for your body of work.

The Training Room

I have been in some institutions that have a very nice room and set up that is conducive to learning.  Unfortunately, I have been in some horrible rooms. Poorly lit, projector with not enough lumens and/or unable to fine tune, screens that have holes, no screens at all, projection on a dirty wall, rooms too small, chairs old and wobbly, not enough chairs, not enough table or desk room, no A/C, no heat, mold on the ceiling, creepy crawlers and/or little critters making cameo appearances.  That is not exactly a prime learning environment. In fact, in my opinion, it is disgraceful. To me, it speaks loudly about upper management’s commitment, or lack thereof, to the quality of their product or service. It would seem that their commitment to excellence leaves a lot to be desired. The investment a company puts into their training is a reflection of the quality of the entire business structure. So let me drop a couple of ideas for the design of your new training room (wishful thinking?). Here are a few suggestions for an effective training space.

  • Well lit with natural light.
  • More than enough room to handle the masses.  No one should feel cramped.
  • No spotlight backsplash (glare from room lights just in front of and above the screen or monitor).
  • Blackout curtains. If none then make sure the projector has enough lumens to see the display in the daylight.
  • Comfortable chairs. There is an old speakers adage that says, “Your mind can only absorb as much as your butt can endure.”
  • Multi configurable tables with sufficient electrical and USB outlets
    • Various table configurations can be made to facilitate attendee interaction depending upon the presentation. This can be very helpful to the overall delivery.
  • Sound. Using the projector for audio is often inadequate. How would Star Wars sound if you heard it on a transistor radio? You don’t have to go overboard but a decent sound system can go a long way. If the room is large you may need microphones. Wireless is the way to go regardless if the mic is handheld, lavailer, desktop, or headset this increases engagement. The instructor can freely move through the room and hand off the mic to further engage attendees. As with the speakers, you don’t have to have the same equipment that Elton John uses but purchase a quality brand…it does matter.
  • Accommodate special needs people, wheelchairs, seeing and hearing.
  • Check the room for exterior noise.
  • Have a contact at the ready to address technical issues when things go sideways.
  • The entrance should be at the rear of the room to minimize distractions of any persons coming and going.

Wrapping it Up:  Achieving An Effective AML Training Course

An effective AML course not only teaches students about AML compliance but exemplifies an institution’s top down approach to quality as well. Your training must take into account global needs. Individual countries have their own regulations when it comes to money laundering. For companies in the U.S. the B.S.A. and The US PATRIOT ACT are the anti-money laundering commandments.  

Thorough AML training courses should provide students with a wealth of information but to be effective, AML training requires far more than information. Money laundering goes much deeper than many realize. In addition to AML knowledge, AML training must provide employees with analytical, investigative, and procedural tools, along with an understanding of how compliant companies, regulators, and law enforcement all work together to fulfill the requirements of a quality AML program and reduce risk. Many AML personnel feel prepared to handle money laundering issues within their institutions but discover after receiving quality AML training that they were missing vital AML details to effectively implement their institutions compliance needs.

This article by no means is the “end all of lists”. Instead, it should be a starter guide to achieving your quality AML training program. A process that should begin by doing your homework.

  • Research your companies AML needs to determine areas needing training or consult with an AML training and advisory professional to assist you with making that determination.
  • Select an AML trainer who can build a customized training program to cover the specific content needed by your institution.
  • Select an AML trainer who while presenting the specified material can identify where employees are struggling or missing information and enhance the material to provide the additional information and reinforcement during the training session.
  • Select the delivery method that works best for you.
  • Create a training space that is conducive to learning, minimizes distractions, and is equipped properly with the needed tools and technical support to present the material.
  • Research the AML training professional you are investing in and validate their credentials.
  • Require a detailed submission of the training agenda. 
  • Don’t invest in a trainer based on a couple of paragraphs written by some marketeer on LinkedIn. Instead choose a trainer who has both the academic background and an applied real world working knowledge of the content they’re teaching to ensure that your investment grows through well trained employees.
  • Choose an AML trainer who will present the material utilizing effective, engaging, and memorable teaching techniques.
  • Education is a lifelong need for all of us making AML training regulatory compliance a recurring event. Evaluate your AML training needs regularly or utilize an AML training and advisory expert to assist you in evaluating those needs. 

A company is only as good as their employees.  Invest in your personnel to provide the quality service and products you expect of your company.

I work with AML programs large and small, if you need a customized and quality anti-money laundering program, training, or advise I invite you to contact me to learn how I can help with your AML compliance. – Kevin Sullivan, CAMS, President of The Anti-Money Laundering (AML) Training Academy.

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About the Author

Kevin Sullivan, CAMS, is a retired New York State Police Investigator and Federal Agent who dedicated his career to AML and continues that work through his company, The AML Training Academy. Kevin coordinated AML investigations for the state of New York while being detailed to one of the worlds largest AML task forces, the NY High Intensity Financial Crime Area (HIFCA) El Dorado Task Force. He has helped develop and implement global AML guidelines and trained and advised all industries and government agencies requiring AML around the globe. He helped to write various certification programs for the Association of Certified Anti-Money Laundering Specialists’ (ACAMS) and was the co-founder and former chair of their inaugural chapter which was in NY. Follow Kevin or reserve a seat in one of his live webinars. Space is limited!

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