(Guideline Chapter 10)

Staff training is an important element of an effective system to prevent and detect ML/TF activities. The effective implementation of even well-designed AML/CTF systems can be compromised if staff using the systems is not adequately trained.

staff trainings

Staff awareness

All staff should be aware of:

  1. GRDA’s statutory obligations and their own personal statutory obligations and the possible consequences for failure to report suspicious transactions under the DTROPO, the OSCO and the UNATMO;
  2. any other statutory and regulatory obligations that concern GRDA and themselves under the AMLO, the DTROPO, the OSCO, the UNATMO and the UNSO, and the possible consequences of breaches of these obligations;
  3. GRDA’s policies and procedures relating to AML/CTF, including suspicious transaction identification and reporting; and
  4. any new and emerging techniques, methods and trends in ML/TF to the extent that such information is needed by the staff to carry out their respective roles with respect to AML/CTF.

AML/CTF training

GRDA implementation include :

  1. Staff would be trained in what they need to carry out in their particular roles with respect to AML/CTF
  2. clear and well-articulated policy for ensuring that relevant staff receives adequate AML/CTF training
  3. GRDA would adjust training methods and assessment according to the size and complexity of the business and the type and level of ML/TF risk
  4. The frequency of training should be sufficient to maintain the AML/CTF knowledge and competence of staff but should in no circumstances less than once every month

Medium of training

All training materials should be up-to-date and in line with current requirements and standards. GRDA training techniques and tools include:

  1. on-line learning systems,
  2. focused classroom training,
  3. relevant videos as well as procedural manuals,
  4. available FATF publications and typologies.

Areas to be covered in training

All New Staff

  1. an introduction to the background of ML/TF and the importance of AML/CTF to the TCSP licensee; and
  2. the need and obligation to identify and report suspicious transactions to the MLRO, and the offence of “tipping-off”.

Front Office Staff

  1. the importance of their roles in GRDA’s AML/CTF strategy being the first point of contact with potential money launderers and persons involved in terrorist financing;
  2. GRDA’s policies and procedures in relation to CDD and record-keeping requirements relevant to their job responsibilities;
  3. guidance or tips for identifying unusual activities in different circumstances that may give rise to suspicion; and
  4. the relevant policies and procedures for reporting unusual activities, including the line of reporting and the circumstances where extra vigilance might be required.

Back Office Staff

  1. appropriate training on customer verification and the relevant processing procedures; and
  2. ways to recognise unusual activities including abnormal settlements, payments or delivery instructions.

Managerial Staff

  1. higher level training covering all aspects of Hong Kong’s AML/CTF regime;
  2. specific training in the AML/CTF requirements applicable to TCSP licensees; and
  3. specific training in relation to their responsibilities for supervising or managing staff, auditing the system and performing random checks as well as the reporting of suspicious transactions to the JFIU.

Money Laundering Reporting Officer

  1. specific training in relation to the MLRO’s responsibilities for assessing suspicious transaction reports submitted to them and reporting of suspicious transactions to the JFIU; and
  2. training to keep abreast of AML/CTF requirements/developments generally.

Training Records

Staff’s training records, including the date and type of training received by each staff will be maintained for a minimum of 3 years and be made available to the CR on demand.

Training effectiveness

GRDA would monitor the effectiveness of the training by:

  1. testing staff’s understanding of the GRDA’s policies and procedures to combat ML/TF, their understanding of relevant statutory and regulatory obligations, and also their ability to identify suspicious transactions; and
  2. monitoring the compliance of staff with GRDA’s AML/CTF systems as well as the quality and quantity of internal reports so that further training needs may be identified and appropriate action can be taken.