Purpose
Ensure personnel receive AML/CTF/CPF training appropriate to their role and that completion evidence is retained.
Scope
This procedure applies to onboarding training, annual refresher training and role-based training for Operations, Compliance and other AML-impacting staff.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Maintain training population | Maintain population of all employees, directors, senior management and AML-relevant contractors/vendors requiring training. All staff involved in client onboarding, transaction processing, compliance, trading, and IT/security must be trained. Senior management and directors must understand oversight responsibilities. Third-party contractors or vendors with AML-related functions must be trained as applicable | In-scope population and role matrix |
| 2 | Assign onboarding and refresher training | Assign AML onboarding training upon hire and annual refresher training to all employees | Training assignment |
| 3 | Assign role-specific training | Assign role-specific training as needed and at least annually where applicable to Compliance, Operations, trading, transaction processing, onboarding and IT/security roles | Training assignment |
| 4 | Deliver ad hoc updates | Deliver ad hoc updates to affected personnel after material legal, regulatory, policy, tool, typology, incident or control change | Training assignment |
| 5 | Deliver training modules | Modules cover both legal/regulatory concepts and internal procedures: AML/CFT/CFP laws and CBCS regulations; ML/TF typologies; CDD, EDD, and Risk Profiling; sanctions screening procedures and red flag indicators; STR/FFR/PNMR reporting obligations; KYT tools, transaction monitoring systems, and alert handling; escalation workflows and documentation standards | Training content version |
| 6 | Use mixed delivery methods | Deliver via combination of e-learning, live sessions, and scenario-based workshops. Use approved external e-learning, CBCS guidance, live instruction and scenario-based exercises. Retain the version of delivered material | Training content version |
| 7 | Assess comprehension | Use knowledge checks, quizzes, or scenario evaluation to assess comprehension. Log attendance and test results in Bitkaya’s compliance system | Assessment result |
| 8 | Remediate failures | Require personnel who do not meet the approved comprehension threshold to repeat training or complete targeted remediation before the gap is closed | Overdue remediation record |
| 9 | Retain training records | Retain training logs, course materials, and attendance records. Compliance Officer is responsible for designing, updating, and monitoring the training program. Training effectiveness is evaluated through audits, feedback, and incident reviews. Program updated regularly to reflect new regulations, typologies, or internal policy changes | Attendance or completion record |
| 10 | Evaluate effectiveness | Evaluate effectiveness through feedback, incident and alert lessons, audits and independent review, and update the programme accordingly | Effectiveness review and improvement record |
| 11 | Retain and report records | Retain assignments, attendance, completion, assessment, remediation and content records and report material gaps to management | Attendance or completion record |
Training Schedule
| Type of Training | Frequency | Audience |
|---|---|---|
| AML Onboarding Training | Upon hire | All new employees |
| Annual Refresher Training | Once per year | All employees |
| Role-Specific Training | As needed or annually | Compliance, Trading, IT |
| Ad Hoc Updates | Upon policy/tool changes | Relevant departments |
Proportionality in Training
Under the proportionality framework, all employees receive AML/CFT onboarding and annual refresher training. Specialized training is delivered only to roles with direct AML/CFT impact (Operations, Compliance). External e-learning and CBCS guidance materials are used in place of developing training materials internally.
Evidence
- training assignment
- attendance or completion record
- assessment result
- overdue remediation record
- training content version
- in-scope population and role matrix
- effectiveness review and improvement record
Relationships
- Policy: POL-AML-001 AML CTF CPF Compliance Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Controls: CTRL-AML-008 Ensure AML Training Is Completed
- Training programme: PROC-TRAIN-001 Govern Training Needs Curriculum Matrix and Calendar, PROC-TRAIN-003 Deliver Recurring and Role Specific Training, PROC-TRAIN-005 Assess Competence and Remediate Gaps
- Manual coverage: sections 1.3, 8.1-8.7 and 14.4.1.4.
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Design status: implemented from approved AML/CTF/CPF Compliance Manual version 2.2
History
- 2026-07-26: Added audiences, schedules, curriculum, delivery methods, assessment, retake and effectiveness requirements after a full manual rescreen.
- 2026-07-26: Created from the approved AML/CTF/CPF Compliance Manual version 2.2.