Question from a firm – As a follow up to last week’s question about the temporary staff and contractors, that work for us perhaps only for a few weeks or a month or so. We ask them to read our in-house AML Policies Controls & Procedures Manual and view the training webinar including the quiz.
What if they ‘fail’ the test? Do we ask them to do it again until they ‘pass’?
Answer – Paragraph 8.5.2 of the latest March 2022 CCAB Guidance on AML states that training ‘records should show the training that was given, the dates on which it was given, which individuals received the training and the results from any assessments.’
If the temporary staff and contractors have already received adequate training in previous positions there is no need to retrain them.
Our recommendation would be that you ask them to carry out your quick multi-choice test on the AML legislation and CCAB guidance. If they obtain a satisfactory score, then keep the results on file with their names/signatures and the date they took the test, as evidence that they were already familiar with the requirements.
If they score badly, then they should be required to undertake the AML training and do a new test. If they still score poorly they should re-sit the test alongside someone who corrects them and explains the answers as they take the test. This should help ensure that they understood the reasoning behind the answers.
Are your AML Policies Controls & Procedures up to date?
We have just released our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
For our latest Audit Quality Control Manual (October 2021) (implementing the latest Irish Audit & Accounting Supervisory Authority standards including ISQC1 on audit quality control) click here. View the Table of Contents here.