The FATF Recommendations include ongoing employee training within the internal controls described in Recommendation 18. They are international standards, not a substitute for the rules and guidance that apply in a particular jurisdiction. A business should confirm its applicable obligations with its compliance specialists.
Start with responsibilities. Map the work performed by customer-facing staff, operational teams, compliance specialists and managers. Identify the decisions, information and escalation routes each group needs to understand. Do not assume every employee needs the same depth on every topic.
Keep the foundation consistent. Explain the business’s approved policies, the purpose of its controls and how colleagues raise concerns. Use current terminology and the reporting routes actually used by the organisation. Make it clear which questions should be referred to a specialist.
Use role-relevant scenarios. A customer-facing example might focus on recognising an unusual request and following an escalation process. An operations example could examine missing information or an exception to a normal workflow. Managers may need practice in supporting staff, checking follow-up and keeping responsibilities clear. These are training-design examples, not instructions for making a regulatory reporting decision.
Check application as well as recall. Ask learners to explain the next step in a realistic scenario and where they would find the approved procedure. Review misunderstandings with the relevant subject owner. Keep the training aligned with changes in products, processes, responsibilities and applicable requirements.
Questions for your compliance lead
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