More and more businesses are catching on 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, quality or length of training. One institution I reviewed believed that a 20 minute YouTube video once a year was sufficient. They were obviously more concerned about their budget and the cost of the training and the cost of their 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 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, the risk appetite, and the level of regulatory actions. While a basic knowledge about money laundering is helpful, it isn’t quite 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 equal. Here are three suggestions for an effective AML course:
These days, just about anyone can create an online course. However, that doesn’t mean that they have the expertise to properly convey the material. While it’s great to self educate and read articles and textbooks about money laundering, in order to adequately and thoroughly teach any subject, it is beneficial 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, and companies also must entrust employees to be qualified to act on behalf of the company. That requires 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 and ask for the bio of the person teaching the course.
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 your time. 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,” etc, etc. What is most important to note is that training is about the student learning. It is not about the instructor looking good wearing a million dollar suit, sounding impressive with 5 syllable words, or name dropping of the all the head honcho’s. So right from the start, the instructor might be distancing himself from the attendees if he is not putting the attendees first. The session then turns into a lecture from some 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, and must be delivered with a “I’m one of you” attitude. 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 into the brains of the attendees. Are they learning? Are they walking out of the classroom retaining and repeating information that was presented? If the instructor can accomplish that, then you have the framework of a good training course.
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 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 delivery of the message.
The two main delivery methods are:
- Online training, including video conferencing, webinar style, and e-training, to name a few and;
- Live on-site training.
Additionally, the training room itself deserves consideration as a delivery method. We’ll talk about this later.
Common shortcomings of many online training courses.
- Boring and not engaging. If attendees are lulled into a coma in the first 15 minutes and then zone out, what good is it? It should be interactive and tell a story that is realist and exciting.
- 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 at all 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. Between webinar and e-training I prefer e-training as it at least forces the student to follow an instruction and select an answer preventing the student from totally zoning out. Further, there should be a graded quiz after the training to review the material and to indicate to the regulator that the staff did take the course and passed an assessment to complete the training.
- Institution who train to satisfy the regulators instead of training employees to understand the topic.
- The inevitable technical issue that drives 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 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.
Shortcomings of live and onsite training:
- Logistics – getting everyone in the same room at the same time
- Who’s steering the ship while everyone is training? Are multiple training dates required?
- Cost to have attendees come to one location. Or the cost of sending instructors to various locations.
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 which provides attendees with the benefits of question/answer sessions, follow up discussions, feedback, group activities, etc. Engaged students have increased retention and understanding of the material.
- One to one with 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. 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 a webinar. Further, you may hear how other people do things and it might spark some new thoughts and ideas 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 all over 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 a quality product. I’m not just talking about quality training, I mean quality up and down the entire business structure. It would seem that their commitment to excellence leaves a lot to be desired. So let me drop a couple of ideas for the design of your new training room (wishful thinking?). Here are a few suggestions for a functional training room.
- Well lit with natural light.
- More than enough room to handle the masses. No one should feel cramped.
- No spotlight backsplash on 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 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 lame. How do you think Star Wars would 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. 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 avoid distractions of attendees coming and going.
Wrapping it Up: Achieving Your Effective AML Training Course
An effective AML course not only teach students about AML compliance but exemplifies them as well. Your training must take into account that individual countries have their own regulations when it comes to money laundering. In the U.S. the B.S.A. and The US PATRIOT ACT are the anti-money laundering commandments.
Thorough AML training courses should load students up with a wealth of information that they provide, 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 fulfil the requirements of a quality AML program. 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 building your quality AML training program. That process 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 your investing in and require a detailed submission of the training agenda.
- Validate the AML trainers credentials and don’t invest in a trainer based on a couple of paragraphs written by some guy 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 reoccuring 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 hated every minute of training, but I said, ”Don’t quit. Suffer now and live the rest of your life as a champion.” – Muhammad Ali
Kevin Sullivan, MS, MMBA, CAMS, was an Investigator with the New York State Police, and he coordinated NY state investigations at the NY HIFCA El Dorado Intelligence Center as a dually designated Federal Agent. Sullivan is a co-founder and former chair of the NY chapter of ACAMS and president of The AML Training Academy. Follow Kevin here.
Pick up a copy of Kevin’s book Anti-Money Laundering in a Nutshell: Awareness and Compliance for Financial Personnel and Business Managers on Amazon.