By delivering the same annual refresher training to all employees, the compliance officer could miss the opportunity to update the staff on any new trends, developments, or risks that have emerged in the anti-money laundering field. For example, new typologies, indicators, technologies, or best practices could be relevant for the staff to be aware of and apply in their daily work. Moreover, the compliance officer could also miss the chance to share any links to enforcement actions identifying violations in other financial institutions that could serve as lessons learned or case studies for the staff to avoid similar mistakes or gaps in their compliance program.
References:
ACAMS CAMS Certification Video Training Course, Module 5: Risk Management, Lesson 5.4:
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ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5: Risk Management, Section 5.4:
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