Counter Terrorism Financing Course
A counter terrorism financing course usually covers indicators well and skips the rule that most often catches staff out, which is tipping off.
Once a suspicious matter report has been made, or is being considered, disclosing that to the customer or to anyone outside the approved process is a separate offence. It carries serious consequences and it is very easy to do by accident.
The realistic scenarios are worth teaching directly. A staff member reassures a customer that their transaction has been flagged and will just take longer. Someone mentions it to a colleague in an open area. A manager explains a delay honestly to keep a client relationship.
All three are well intentioned and all three create exposure. The safe practice is a single agreed form of words for explaining any delay, used by everyone, so that nobody has to improvise under pressure at the counter.
AUSTRAC publishes guidance for reporting entities. This is general information rather than legal advice.
See Sentrient’s AML/CTF course and code of conduct training.
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