AML/CTF Programs
1.0 - Fundamentals of AML/CTF programs 2.0 - AML/CTF program: Part A (general) 3.0 - AML/CTF program: Part B (customer identification) 4.0 - Risk assessment for your AML/CTF program 5.0 - Implementing and monitoring your AML/CTF program
 

5.3 Program implementation tools (continued)

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Possibly the most important measurement of how well your AML/CTF training works is to assess the behaviour of trainees in the workplace some time after the training, to assess whether the trainee is applying and displaying in the workplace the knowledge, skills and attitudes learnt during the training. This can be assessed approximately 1-3 months after the training has taken place. This is to allow the trainee sufficient time to adapt and implement his or her new skills and knowledge. Methods of assessment may include:

  • observations and interviews over time
  • objective and ongoing assessment of behaviour over time
  • self assessment using carefully designed criteria and measurements
  • surveys with appropriate questions.

Recording these evaluations is a source of evidence of the application of AML/CTF behaviours in everyday business and the effectiveness of the link between AML/CTF training and normal business practices.

Finally, the cumulative results of the AML/CTF training on the business can be assessed over a timeframe of 6-12 months. Effective training and application of learning should show as an improvement in the business's performance to achieve the goals of its AML/CTF program. Year-to-year comparisons of the business, using an instrument like AUSTRAC's AML/CTF Self Assessment Questionnaire (SAQ), can show improvements related to the training that has been conducted and in turn identify new training objectives where deficiencies in AML/CTF capabilities exist. Other business results that can be recorded include:

  • the number of trainees that participated in training
  • the proportion of the trainees reaching a training standard
  • the opinions and awareness of employees regarding AML/CTF issues sought through employee opinion surveys
  • statistics relating to compliance with processes and reporting.

Training records that are kept as a matter of normal business practice can help determine the AML/CTF progress and attainments of individual trainees and when they may require refresher training. Training records derived from an evaluation framework such as Kirkpatrick's model may provide evidence of the successful implementation of the AML/CTF program and assist in maintaining compliance.

 

 

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Last updated: Friday, 28 October, 2011