ABSTRACT
The Financial Services Authority (FSA) considers training to be separate from awareness. Under their Rules, the FSA requires the institution to take reasonable steps to provide appropriate anti-money laundering training for its employees who handle, or are managerially responsible for the handling of, transactions which may involve money laundering. The FSA requirements far exceed the basics required by the law and are far more comprehensive. The FSA goes further, in that it states that it is the money laundering reporting officer’s specific responsibility to ensure that awareness and training requirements are met. While everyone must receive refresher training at least every two years, certain positions and functions may require a more frequent training/awareness regime. No matter how awareness or training is provided or by whom, it is essential that proper records are kept. These records must show who has been trained and when, what training was provided and some means of ensuring that they understood the training.
