PART II – The FATF/GAFI Approach to Continuing Education

by Alfonsina Leo – MEF Executive – Head of the Italian FATF/GAFI Delegation

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This contribution continues the series of insights we are dedicating to certifications AMLACERT® and CAMS of ACAMS and their strategic role in AML/CFT compliance. Following the introductory article published last week, this second contribution offers an institutional perspective: Dr. Alfonsina Leo, Director of the Ministry of the Economy and Finance and Head of the Italian Delegation to the Financial Action Task Force (FATF)/FATF, illustrates the importance of continuous training in international standards and the link with the effectiveness of anti-money laundering measures.

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The FATF/GAFI recommendations and the centrality of training

The recommendations of the Financial Action Task Force (FATF)The FATF (Financial Action Task Force) represents the international standard for preventing money laundering, terrorist financing, and the proliferation of weapons of mass destruction. They are an essential reference point for obliged entities—financial institutions, professionals, and non-financial operators—in properly fulfilling their anti-money laundering obligations, from risk self-assessment and customer due diligence to the obligation to abstain and report suspicious transactions.

For this reason, among the fundamental principles outlined by the Financial Action Task Force (FATF)/FATF, particular emphasis is placed on the continuous training of staff and the adoption of adequate internal control systems, essential tools to ensure the effectiveness of anti-money laundering measures.

Recommendation 18: Training as an operational pillar

La continuous training, explicitly referred to in the Recommendation 18 [1], is considered a key element to ensure that all obliged entities – including employees, managers and collaborators – are able to promptly recognize suspicious transactions and adopt the correct risk mitigation measures.

Il Financial Action Task Force (FATF)/FATF emphasizes that the lack of adequate preparation exposes organizations to serious vulnerabilities, making them unwitting tools for illicit activities. For this reason, it is essential that training programs are periodic, targeted, updated with respect to the evolution of recycling techniques[2] and national and international regulations and aimed at providing practical tools for identifying and reporting suspicious transactions.

Staff training is therefore a key element of a Programme AML/CFT Effective. Only through constant training can the Anti-Money Laundering Officer effectively carry out his duties, helping to protect the integrity of the financial system and prevent the illicit use of economic channels and his own responsibilities.

The transition from the rule-based approach to the risk-based approach

At the same time, the internal control system and company procedures must be consistent with the risk profiles and proportionate to the nature, size, and complexity of the activity performed. According to the Recommendation 1 of the Financial Action Task Force (FATF)/GAFI, in fact, the obliged entities must adopt a risk-based approach, which involves the assessment and proactive management of money laundering risks, through the definition of effective policies, procedures and control measures[3].

The FATF/GAFI evaluation reports on national systems for preventing and combating money laundering reveal that the transition from a rule-based to a risk-based approach is a challenging task. Obliged entities require a solid understanding of risks, a solid legal basis (regulating mandates and powers), an organizational structure, and adequate preparation and resources to successfully implement a robust risk-based supervisory approach.

Il Financial Action Task Force (FATF), in its reports, often highlights shortcomings precisely in the training front in the countries examined: the cultural change needed to implement a risk-based approach also and above all requires structured and continuous training programs, in addition to the development and implementation of a comprehensive surveillance toolkit.

International certifications as a lever to meet FATF standards

Regarding training, the FATF's guidance on risk-based supervision, along with internal controls and audits, includes "continuous staff training" as an essential component of an effective compliance program, highlighting how adequate training is necessary within organizations to support an effective AML/CFT risk-based supervisory framework. Training is required at all levels, from employees to managers and board members.

In the guidance[4] on risk-based supervision[5], the Financial Action Task Force (FATF) includes the continuous staff training as an essential part of an effective compliance program, highlighting how appropriate training is necessary within organizations to support an effective AML/CFT risk-based supervisory framework, alongside internal controls and audits. This training is required at all levels: operational employees, managers and board members.

Il Financial Action Task Force (FATF) recognises that the ability of operators to identify, assess and manage money laundering risks depends significantly on the quality of training received. In this framework, internationally recognized training courses, such as certifications AMLACERT® and CAMS (Certified Anti-Money Laundering Specialist), represent particularly effective tools to meet FATF standards: acquiring certified skills strengthens both the ability to detect and manage risks and the overall credibility of the internal compliance system.

Have a certification such as CAMS di ACAMS o AMLACERT therefore it becomes one quality assurance for financial institutions and supervisory bodies, demonstrating that the professional has followed a training path consistent with international standards Financial Action Task Force (FATF) and is able to proactively address money laundering threats.

Therefore, AMLACERT® and CAMS of ACAMS not only do they respond promptly to the recommendations of the Financial Action Task Force (FATF) in terms of ongoing training, but they also represent a strategic compliance and reputational tool, which strengthens the culture of prevention within organizations, reducing the risk of sanctions and contributing to the construction of a more solid and effective anti-money laundering system.

In conclusion, this contribution shows how standards Financial Action Task Force (FATF) and certifications AMLACERT® and CAMS of ACAMS are perfectly aligned: both aim to create professionals capable of dealing with the most complex and innovative risks.

For organizations, integrate certified figures through programs such as the International Executive Master AML/CFT Diploma – Including AMLACert and CAMS – which allows you to obtain both certifications – means equipping yourself with the highest level of available skills and ensuring your Board of Directors is supported by global best practices, strengthening your legal and reputational protection.

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[1] Recommendation 18 – See //www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/FATF%20Recommendations%202012.pdf.coredownload.inline.pdf

[2] The Recommendation 15 draws attention to the importance of continuously adapting internal controls to new technologies, digital services, and potential emerging threats, such as money laundering through crypto-assets.

[3] The Recommendation 17Furthermore, it requires that the obligated entities equip themselves with mechanisms for constantly monitoring operations and customers, in order to promptly identify any anomalies or suspicious behavior.

[4] In order to support jurisdictions, the FATF/GAFI develops guidance.

[5] See FATF guidance Risk Based Supervision March 2021 Guidance-Risk-Based-Supervision.pdf.coredownload.inline.pdf

[5] Cfr risk-based approach guidance for legal professionals;

[5] https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/RBA-Accounting-Profession.pdf.coredownload.pdf.

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