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FC-6.1.1

A licensee must take reasonable steps to provide periodic training and information to ensure that staff who handle customer transactions, or are managerially responsible for such transactions, are made aware of:

(a) Their responsibilities under the AML Law, this Module, and any other relevant AML/CFT laws and regulations;
(b) The identity and responsibilities of the MLRO and his deputy;
(c) The potential consequences, both individual and corporate, of any breach of the AML Law, this Module and any other relevant AML/CFT laws or regulations;
(d) The licensee's current AML/CFT policies and procedures;
(e) Money laundering and terrorist financing typologies and trends;
(f) The type of customer activity or transaction that may justify an internal report in accordance with Section FC-5.1;
(g) The licensee's procedures for making internal report in accordance with Section FC-5.1; and
(h) Customer due diligence measures with respect to establishing business relations with customers.
October 2010