Financial Crime Compliance training - 5 keys to keep it engaging and legal

Compliance training has been a prerequisite within all firms today, more so, when someone joins larger organisations there are more than 15 short courses that staff must complete and pass the end for them to move on. This is pretty much the threshold to satisfy senior management that they have effectively carried out their regulatory duties. whilst carrying out their impersonal, generic online learning process. Some people even utilise innovative methods to circumvent the course by screenshots, flicking through all the answers or asking a colleague to complete the rest of the assessment on their behalf. 

What senior management fail to realise is, they are creating a tick-box mentality mindset, because all their staff have experienced from their financial crime compliance training is, ‘How do I get passed this and move on?’ 

Within a recent interview the president of the Financial Action Task Force (FATF), Dr Marcus Pleyer highlighted tailored training as being one the key factors to combat financial crime, which includes money laundering, terrorist financing, tax evasion, corruption etc. alongside adopting new technologies and information sharing.  

I have not only been a qualified teacher but a subject matter expert and trainer to all things anti-financial crime. My mission (and passion) is to educate others and for my clients, how we can create an immersive tailored training experience within the budgetary requirements that many pay for their off-the-shelf general eLearning courses. Regulators a looking deep within the training framework of firms to confirm if firms are sticking to the Training and Competence (T&C) regime designed to influence culture.

I take time out to speak with my clients prior to designing, developing and delivering online training throughout and often have to be very creatively innovative to achieving the end product as I include tailored (firm-specific desk-top-procedure-type operational) assessment questions, current affairs (i.e. recent sanctions and/or financial crime events), real-life case studies alongside outcomes (often overlooked) and providing them with a certification of achievement at the end confirming specific topics covered (rather than a general attendance / completion record). 

Many of my clients have decided to use this pandemic as an opportunity to update their staff AML/CFT and Sanctions training by refreshing their eLearning units on Anti-Financial Crime, as a result they get in touch with myself, my role is to use what they have provided and include the following five things to make the course an immersive experience. 

Throughout the feedback received I have deemed these five points to be a best practice for all financial crime compliance training. Here follows the five questions I ask myself when developing the training material:

1. Has the T&C been planned and Governance approved (as part of the SMCR)?

I usually get a blank look when I ask this question, followed by the phrase, ‘well… yes..’ I then ask when it was approved and that is when the alarm bells start ringing. The person I’m dealing with usually informs me that it was endorsed a few years ago, I have even been told that it was endorsed over 10 years ago, which automatically makes the training obsolete. 

Due to the Senior Management Certification Regime (SMCR) and Senior Management Functions (SMF), senior managers now have a number of responsibilities that they have to personally provide a SoRs or Statement of Responsibilities (alongside Identification of certified staff, Training and Competence, Conduct rule breaches and Firm culture) for the regulators to gain confidence in the governance of the firm. 

One of the most crucial elements of the SMCR role is to keep their firm’s training in-line with the Training and Competence (T&C) regime. A firm’s Governance/Board must make sure they approve T&C according to the T&C regime led by senior management, making sure they know what the high-risk areas and complex role-specific training requirements are and to evidence the fact that this will be the T&C plan rolled out for the year ahead – they can no longer leave it to HR to process. 

2. Is it tailored (role-specific) training?

Regulators are now focusing on the impact on a firm’s culture that senior management are having and one of the key elements is T&C. With more specified products and services combined with new technologies, the generic law and regulation focused training is no longer fit-for-purpose. The training must have the following factors in place:

• Critical thinking; the thinking process should be in line with the operational duties that the trainee would be carrying out to spot the red flags before it is too late
• See the bigger picture; using updated case studies deep diving into what led to where allows the learner to not only be engaged but opens their thought process to a wider scope that their contribution can bring
• Tone from the top; many have come across this term, but within training there has to be a team effort from the leaders of the firm to let staff know that they are all in this fight against human trafficking, drugs etc together and the reputational damage that this may cause to the firm if overlooked, if anything, a message from the leaders would make the staff feel more valued and a sense of belonging.

3. Is it inclusive and does it have a method of differentiation?

When I first came across the term differentiation, I was a young teacher, as I looked into it a lightbulb went off in my head. Suddenly things made sense, now I use differentiation methods all the time. Differentiation is a term used to address all learners not just those who are fast readers and keep a strong short-term memory but those who learn at slower paces but retain the information within their longer-term memory.

As we adopt more technologies [new global digital banking and/or FinTechs offering a stable cryptocurrency (Stablecoins)], our teaching methods should be able to address these differences in culture, background (from traders to programmers) and most importantly, at the pace of the learner. Remember, we are not ticking-a-box here, we are creating a paradigm shift and when it comes to changing someone’s mental syntax, there is never a one-pace-sets-all approach.

The learning has to be (1) flexible and (2) collaborative along with (3) progressive tasks (Bloom’s Taxonomy), (4) digital resources, (5) verbal support, (6) variable outcomes and an (7) ongoing assessment. 

I would further define these seven elements, but it would take over the topic of the article, but well worth looking into, e.g. (2) collaborative learning alone requires group/team work, learning from their peers and a way of getting involved with colleagues that one would on a real-life case – almost like a practice run which solidifies the operational processes within the learner’s mental syntax.

I have met many genius programmers, traders and CEOs who are dyslexic, worked better with numbers and/or found it very difficult to adopt regulations within their business models. They all required a different learning approach and they all understood their respective roles and mission by the end of the course. Inclusion and differentiation are two different teaching methods used to reach learners regardless experience and level of understanding.

4. Is there a certified record of achievement?

I worked with a global bank training their risk managers to become expert at fraud detection. We created an immersive training experience with various certifications as they passed their assessments. The assessments were essay-based answers where each group was given a particular real-life case study to deep dive and examine, each and every case study was from their own bank, so they knew where to go for more information and how to evidence the points raised within their essay. 

The learners not only passed their current tailored course but framed their certification for them to reflect back on how much they enjoyed their training, each time they reflected back they recalled a few highlights on the case that they went through and the collaborative work that they all did to achieve their earned certification.

Not only was the course enjoyable, but every single person who took the assessment passed with distinction and senior managers were happy as they could present the whole course, along with the framework and approvals as evidence being part of the SMCR duties.

5. Do we have an ongoing mission?

Keep the learning ongoing as a team, this is more for the respective team leads to engage with their respective teams and senior management on new cases that come to light, the cases should be highlighted and sent through from Financial Crime Compliance to show relevance of the case to the firm. Team leads are to use team huddles to redefine various learning points from news articles, case studies and how it concerns their specific role had such an event occurred within their respective departments.