The AML/CFT Act (S57 (b)) states that your AML/CFT programme must have effective procedures, policies and controls for training on AML/CFT matters for the following employees:

• Senior managers.
• The AML/CFT compliance officer. 
• Any other employee that is engaged in AML/CFT related duties.

In the AML/CFT Programme Guideline a senior manager is described as  “… a company director or anyone in your business in a position to influence the management or administration of the business.” 

Your programme should set out which positions in your organisation are “senior managers”. It could be a company director, trustee of a trust, partner in the business or other senior managers such as the chief executive or the chief financial officer.

The next step is to develop or seek out training material that covers the responsibilities of a senior manager in an AML/CFT context. While senior managers may never be directly involved in tasks like verifying proof of address they bear the ultimate responsibility for these actions. 

Below is an overview of the responsibilities of senior managers as well as important things to consider.

It is the responsibility of senior managers to ensure that: 

• All appropriate staff are trained to the appropriate level.
• Training is tailored for each subgroup of staff as listed above.
• The compliance officer receives additional training. 

It is also good practice for a senior manager to:

• All appropriate staff are trained to the appropriate level.
• Training is tailored for each subgroup of staff as listed above.
• The compliance officer receives additional training. 

Finally, when it comes to management reports here are some of the things that should be included to give senior managers the assurance they are looking for:  

• Results of transaction monitoring. 
• Number of suspicious activity reports. 
• Progress of staff training.
• Any issues or findings from the internal assurance programme. 
• Any media Items of interest.
• Results of independent audits.
• Updates from the supervisors. 
• Any other compliance issues. 

If you have any questions about AML/CFT training for senior managers and how it applies to your business don’t hesitate to get in touch with our team.