Do you know that Nigerian law mandates all financial institutions to develop training programmes for its entire staff?
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Money Laundering (Prohibition) Act 2011 as amended states under section 9 (1) that;
Every Financial Institution and Designated Non-Financial Institution shall develop programmes to combat the laundering of the proceeds of a crime or other illegal acts, and these shall include-
(a )the designation of compliance officers at management level at its headquarters and at every branch and local office;
(b) regular training programmes for its employees;
(c) the centralization of the information collected; and
(d) the establishment of an internal audit unit to ensure compliance with and effectiveness of the measures taken to enforce the provisions of this Act.
(2) Notwithstanding the provision of this Act or any other Law, the Central Bank of Nigeria, Securities and Exchange Commission, National Insurance Commission or any other relevant authority may-
(a)impose a penalty of not less than N 1,000,000 for capital brokerage and other financial institutions and N 5,000,000 in the case of a Bank; and
(b) in addition, suspend any license issued to the Financial Institution or Designated Financial Institution,
For failure to comply with the provisions of subsection (1) of this section
Meanwhile the Securities and Exchange Commission AML/CFT regulations 2013, also mandates operators to get trained
24 - (1) A Capital Market Operator shall design a comprehensive employee education and training programmes not only to make employees fully aware of their obligations but also to equip them with relevant skills required for the effective discharge of their AML/CFT tasks; provided that the timing, coverage and content of the employee training programme shall be tailored to meet the perceived needs of the Capital Market Operator.
(2) The employee training programmes shall be developed under the guidance of the AML/CFT Chief Compliance Officer in collaboration with the top Management; and the basic elements of the employee training programmes shall include—
(a) AML regulations and offence; (b) the nature of money laundering ; (c) Money laundering red flags‘ and suspicious transactions, including trade-based money laundering typologies ; (d) reporting requirements ; (e) Clients Due Diligence; (f ) risk-based approach to AML/CFT; and (g) record keeping and retention policy..
The NAICOM Anti-Money laundering and countering the financing of terrorism regulations 2013 is not left out.
19. – (1) An insurance institution shall design and implement comprehensive AML/CFT training programme that will make employees and agents to be fully aware of their obligations and also equip them with relevant skills required for the effective discharge of their AML/CFT compliance tasks.
(2) For the purpose of sub-regulation(1) of this regulation, an insurance institution shall consider the training that is appropriate for each category or level of its employees and ensure that each training shall be on-going and shall keep pace with the dynamism of money laundering and terrorism financing
(3) Insurance operators and brokers shall ensure that their employees, agents and any other persons doing business with them clearly understand the AML/CFT programme.
From above, you will see that training is mandatory and cannot be wished away. The various AML laws mandate every operator in the financial sector to be trained. Training programmes must be designed and driven by the chief compliance officer. It is the duty of the CCO to ensure staff are fully aware of their obligations and also to get them skilled with the requisite knowledge needed to discharge their functions effectively.
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