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Banking and payment services: AML/CFT – is e-learning enough to comply with training obligations?

Banking and payment services: AML/CFT – is e-learning enough to comply with training obligations?

Under art. 52 of the Polish AML Act each obliged institution shall ensure the participation of persons performing obligations related to counteracting money laundering and terrorist financing in training programs related to the implementation of these obligations.

In practice this means that every person (employee, associate, director etc.) involved with implementation of AML/CFT related obligations (e.g. onboarding of customers, sale, screening, customer service, transactions, SAR filings etc.) shall be an AML/CFT trained professional, whereas the trainings should be repeated periodically.

One of frequently asked questions is - how should a proper AML/CFT training look like?

Internal vs. Outsourced

Both options comply with the provisions of AML Act, provided that the training is performed by an individual or entity with proper experience and education. Bigger entities quite often perform trainings internally, as it is more cost-effective. However, it is quite the opposite for smaller entities, which can outsource the training to a third party entity.

Public vs. Private

Again, both options (trainings outsourced to entities from public and private sector entity) comply with the provisions of AML Act, provided that the training is performed by an individual or entity with proper experience and education. It is somewhat presumed that a training performed by public authorities complies with AML Act.

Online vs Offline

Both options are correct. In fact there are some public e-learning solutions made available by the Ministry of Finance, as for now only in Polish.

We invite you to contact our Law Firm, which offers services such as:

  1. designing AML policies and drafting necessary documentation,
  2. performing AML/CFT related training programs.


Piotr Putyra

Lawyer

Piotr Putyra

Barrister, Partner

Piotr Putyra

Contact:

Rondo ONZ 1
00-124 Warsaw