Objective
Ensure AML/CTF/CPF training is assigned, completed and remediated according to role and risk.
Control Activity
Compliance maintains the in-scope population and tracks onboarding training for new personnel, annual refresher training for all employees, role-specific training for AML-impacting roles and event-driven updates. Attendance, content versions and assessments are retained; failed comprehension requires retake or targeted remediation; and effectiveness is evaluated through feedback, incidents and assurance.
Who Must Be Trained
- All staff involved in client onboarding, transaction processing, compliance, trading, and IT/security
- Senior management and directors (to understand oversight responsibilities)
- Third-party contractors or vendors with AML-related functions (as applicable)
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 |
Training Topics
Training modules cover both legal/regulatory concepts and internal procedures, including:
- Overview of AML/CFT/CFP laws and CBCS regulations
- Understanding of money laundering and terrorist financing typologies
- Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Risk Profiling
- Sanctions screening procedures and red flag indicators
- STR/FFR/PNMR reporting obligations
- Use of KYT tools, transaction monitoring systems, and alert handling
- Escalation workflows and documentation standards
Delivery & Assessment
- Training is delivered via a combination of e-learning, live sessions, and scenario-based workshops
- Knowledge checks and quizzes are used to assess comprehension
- Attendance and test results are logged in Bitkaya’s compliance system
- Staff who fail to meet minimum comprehension thresholds must retake training
Documentation & Oversight
- Training logs, course materials, and attendance records are retained
- The Compliance Officer is responsible for designing, updating, and monitoring the training program
- Training effectiveness is evaluated through audits, feedback, and incident reviews
- Program is updated regularly to reflect new regulations, typologies, or internal policy changes
Evidence
- Expected evidence: training roster.
- Expected evidence: completion report.
- Expected evidence: assessment result.
- Expected evidence: remediation record.
- Expected evidence: role matrix, training schedule and content version.
- Expected evidence: effectiveness review and improvement action.
- Evidence location: compliance evidence repository and applicable operating system.
- Retention: according to Bitkaya AML/CTF/CPF record-retention requirements.
- Testing method: Reconcile employees, directors, senior management and relevant contractors or vendors to the required onboarding, annual, role-specific and event-driven training; sample curriculum, assessment, retake, overdue escalation and effectiveness evidence.
- Testing frequency: annual, and after material AML/CTF/CPF changes where applicable.
Relationships
- Policy: POL-AML-001 AML CTF CPF Compliance Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Procedures: PROC-AML-008 Deliver AML Training and Awareness
- 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 complete audience, schedule, curriculum, assessment, retake and effectiveness testing after a full manual rescreen.
- 2026-07-26: Created from the approved AML/CTF/CPF Compliance Manual version 2.2.