Question from a firm – From time to time we have temporary staff and contractors, 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 AML training webinar including the quiz. Are we being over-zealous by insisting on this?
Typically the level of client contact for temporary/contractor staff will be low, but they will take phone calls, see incoming correspondence/e-mails and so on. It is conceivable that they could be the first person here, or perhaps the only one, to become aware of a money laundering issue.
Answer -Section 54 of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021 requires ‘persons involved’ to be given training. Section 54 (10) defines ‘persons involved’ as including ‘a reference to directors and other officers, and employees, of the designated person’ so that will include temporary/contractor staff. It is irrelevant whether they have face to face client contact or not.
The safest option would be to provide training to all employees including temporary/contractor staff as they may come across suspicious activity, in the course of their work that needs reported to the MLRO. It is best practice to retain records of the training including the materials used, the date, names/signatures of the attendees and the results of the quiz that helps prove their understanding of the topic.
For more on this topic see the newly created Chartered Accountants Ireland AML Technical Hub.
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