A test to test the knowledge of employees of organizations that carry out transactions with funds. Test to test the knowledge of employees of organizations carrying out transactions with funds Compliance primary test of knowledge on FT

Chapter 4. AML/CFT training and education program and recording of training completed by employees

4.1. A non-credit financial institution, with the exception of an insurance broker who is an individual entrepreneur and does not have employees with whom employment contracts have been concluded, develops an AML/CFT training and education program.

The AML/CFT training program is approved by the head of the non-credit financial organization.

4.2. The AML/CFT training and education program should include:

a) study of legislative acts Russian Federation, regulations of the Bank of Russia and other regulations of the Russian Federation in the field of AML/CFT;

b) study of rules and implementation programs internal control in a non-credit financial institution when performed by an employee job responsibilities, as well as measures of liability that can be applied to an employee of a non-credit financial organization for failure to comply with legislative acts of the Russian Federation, regulations of the Bank of Russia, other regulatory legal acts of the Russian Federation in the field of AML/CFT and internal documents of a non-bank financial organization adopted for the purpose of organizing and implementation of internal control;

c) study of typologies, characteristic patterns and methods of laundering criminal proceeds and financing of terrorism, as well as criteria for identifying and signs of unusual transactions;

d) testing the AML/CFT knowledge of employees of a non-credit financial institution.

4.3. The AML/CFT training program should be reviewed on a periodic basis (at least once a year) by the responsible officer.

4.4. In non-credit financial organizations, the initial assessment of the AML/CFT knowledge of employees of a non-bank financial organization is carried out after one month from the date of the introductory (primary) briefing.

The form and procedure for testing the AML/CFT knowledge of employees of a non-bank financial organization are determined by the non-bank financial organization independently.

4.5. A non-credit financial institution must keep records of training completed by its employees.

The procedure for maintaining such records is established by the head of the non-credit financial organization.

The fact that an introductory (primary) and targeted (unscheduled) briefing was conducted with an employee of a non-bank financial organization must be confirmed by his handwritten signature in a document, the form and content of which is established by the non-bank financial organization independently.

4.6. Documents (or copies thereof) indicating that an employee of a non-credit financial organization has completed AML/CFT training are kept in the employee’s personal file for the entire duration of his work in the non-credit financial organization. It is allowed to store these documents in electronic form.

T E S T

testing the knowledge of employees of organizations carrying out transactions with funds or other property of the requirements of legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism

1. Legalization (laundering) of proceeds from crime is:

a) possession, use or disposal in cash or other property obtained as a result of the commission of a crime.

b) giving legal form to the possession, use or disposal of funds or other property obtained as a result of committing a property crime;

c) giving legal form to the possession, use or disposal of funds or other property obtained as a result of the commission of a crime, with the exception of crimes provided for in Articles 193, 194, 198, 199, 199.1 and 199.2 of the Criminal Code of the Russian Federation;

2. Financing of terrorism is:

a) providing or collecting funds or providing financial services with the understanding that they are intended to finance an organized criminal community and its organizations, the preparation and commission of crimes provided for in Articles 206, 193, 194, 198, 199, 199.1 and 199.2 of the Criminal Code of the Russian Federation;

b) provision or collection of funds or provision of financial services with the knowledge that they are intended to finance the organization, preparation and commission of at least one of the crimes provided for in Articles 205, 205.1, 205.2, 206, 208, 211, 277, 278, 279 and 360 of the Criminal Code of the Russian Federation, or to support an organized group, illegal armed group or criminal community (criminal organization) created or being created to commit at least one of these crimes;

c) provision or collection of funds or provision of financial services with the knowledge that they are intended to finance the organization, preparation and commission of at least one of the crimes provided for in Articles 205, 205.1, 205.2, 206, 208, 211, 220, 221, 277, 278, 279 and 360 of the Criminal Code of the Russian Federation, or to support an organized group, illegal armed group or criminal community (criminal organization) created or being created to commit at least one of these crimes;

3. Internal control is:

a) the activities of organizations carrying out transactions with funds or other property to identify transactions subject to internal control;

b) the activities of organizations carrying out transactions with funds or other property to identify transactions subject to mandatory control;

c) the activities of organizations carrying out transactions with funds or other property to identify transactions subject to mandatory control and other transactions with funds or other property related to the legalization (laundering) of proceeds from crime and the financing of terrorism.

4. The organization of internal control is:

a) a set of measures taken by organizations carrying out transactions with cash or other property, including the development of internal control rules, the appointment of special officials responsible for the implementation of internal control rules;

b) a set of measures taken by organizations carrying out transactions with funds or other property, including the development and approval of internal control rules and programs for its implementation;

c) a set of measures taken by organizations carrying out transactions with funds or other property, including the appointment of special officials responsible for compliance with the specified rules and implementation of the specified programs.

5. Implementation of internal control is:

a) implementation by organizations carrying out transactions with cash or other property of internal control rules and programs for its implementation, as well as compliance with legal requirements for documenting information (information) and their submission to the authorized body, for storing documents and information, for preparing and personnel training;

b) implementation by organizations carrying out transactions with funds or other property of internal control rules, as well as compliance with legal requirements for identifying clients, their representatives, beneficiaries, for documenting information (information) and submitting them to the authorized body, for storing documents and information on training and education of personnel;

c) implementation by organizations carrying out transactions with funds or other property of internal control rules and programs for its implementation, as well as compliance with legal requirements for identifying clients, their representatives, beneficiaries, for documenting information (information) and submitting them to the authorized body.

6. Does the ban on informing clients and other persons about measures taken to combat legalization (laundering) of proceeds from crime and the financing of terrorism apply to measures aimed at combating the legalization (laundering) of proceeds from crime and the financing of terrorism:

a) no, it does not apply, such an obligation does not exist;

b) yes, applies only to persons in relation to whom there is information about their involvement in extremist activities or terrorism, or a legal entity directly or indirectly owned or controlled by such an organization or person, or an individual or legal entity acting on behalf of or at the direction of such organization or person;

c) yes, it does.

7. A transaction with funds or other property is subject to mandatory control if:

a) the amount for which it is made is equal to or exceeds 600,000 rubles or equal to or exceeds an amount in foreign currency equivalent to 600,000 rubles, and by its nature relates to the provision by legal entities that are not credit institutions of interest-free loans to individuals and (or ) other legal entities, as well as receiving such a loan;

b) the amount for which it is made is equal to or exceeds 3,000,000 rubles or equal to or exceeds an amount in foreign currency equivalent to 3,000,000 rubles, and by its nature relates to the provision by legal entities that are not credit institutions of interest-free loans to individuals and (or ) other legal entities, as well as receiving such a loan;

c) the amount for which it is made is equal to or exceeds 600,000 rubles or equal to or exceeds an amount in foreign currency equivalent to 600,000 rubles, and by its nature relates to the provision by legal entities that are not credit institutions of any loans to individuals and (or ) other legal entities, as well as receiving such a loan;

8. A transaction with funds or other property is subject to mandatory control if:

a) the amount for which it is made is equal to or exceeds 600,000 rubles or equal to or exceeds an amount in foreign currency equivalent to 600,000 rubles, and by its nature refers to the contribution by a person to the authorized (share) capital of the organization of funds;

b) the amount for which it is made is equal to or exceeds 600,000 rubles or is equal to or exceeds an amount in foreign currency equivalent to 600,000 rubles, and by its nature refers to the contribution by an individual to the authorized (share) capital of the organization of funds in cash ;

c) the amount for which it is made is equal to or exceeds 600,000 rubles or is equal to or exceeds an amount in foreign currency equivalent to 600,000 rubles, and by its nature refers to the contribution by a legal entity of funds in cash to the authorized (share) capital of the organization ;

9. A real estate transaction is subject to mandatory control if:

a) the amount for which it is committed is equal to or exceeds 3 rubles or is equal to or exceeds an amount in foreign currency equivalent to 3 rubles, and the result of its commission is the transfer of ownership;

b) the amount for which it is made is equal to or exceeds 600,000 rubles or equal to or exceeds an amount in foreign currency equivalent to 600,000 rubles;

c) it is accomplished by payment in securities in the amount of 600,000 to 3 rubles;

10. The client must be identified if he:

a) only performs an operation (transaction) subject to mandatory control;

b) only if employees of an organization carrying out transactions with funds or other property, based on the implementation of internal control programs, suspect that any operations are carried out for the purpose of legalizing (laundering) proceeds from crime or financing terrorism;

c) performs any operation (transaction), with the exception of an individual carrying out an operation to buy or sell cash foreign currency in an amount not exceeding rubles or not exceeding an amount in foreign currency equivalent to rubles;

d) A and B are correct.

11. In what case will a special official comply qualification requirements m:

a) availability of higher professional education in the specialty “Jurisprudence”, confirmed in the prescribed manner, completion of training in order to combat the legalization (laundering) of proceeds from crime and the financing of terrorism in the form of unscheduled instruction;

b) having at least two months of work experience in positions related to the performance of duties to combat the legalization (laundering) of proceeds from crime and the financing of terrorism and completion of training in order to combat the legalization (laundering) of proceeds from crime and the financing of terrorism in the form of targeted instruction;

c) presence of higher education vocational education in specialties belonging to the group of specialties “Economics and Management”, or in the specialty “Jurisprudence”, belonging to the group of specialties “Humanities and Social Sciences”, confirmed in the prescribed manner, and in the absence of the specified education - at least two years of work experience in positions related to the performance of duties to combat the legalization (laundering) of proceeds from crime and the financing of terrorism and undergoing training in order to combat the legalization (laundering) of proceeds from crime and the financing of terrorism in the form of targeted instruction.

12. What kind of briefing are we talking about, if it is carried out by a special official when hiring for positions or to perform the functions specified (specified) in paragraphs 3, 4 of the Regulations, and during transfer (temporary transfer) to positions or to perform functions , specified (indicated) in paragraphs 3, 4 of the Regulations.

a) planned;

b) unscheduled;

c) target;

d) introductory.

13. One-time training for AML and CFT purposes in the form of targeted instruction is provided for:

a) special officials;

b) heads of organizations (branch);

c) deputy heads of organizations (branches);

e) the head of a legal department or a lawyer of the organization;

f) a, b, c, d, e are correct;

g) a, b, c, d are correct.

14. For how long is the organization required to suspend the operation if at least one of the parties is an organization or individual in respect of which there is information obtained in the prescribed manner about their participation in terrorist activities, or a legal entity directly or indirectly owned or controlled control of such organization or person, or a person or legal entity acting on behalf of or at the direction of such organization or person:

a) for three working days;

b) for two working days;

c) for 10 working days.

15. What regulatory document defines a unified approach to the development of organizations (with the exception of credit institutions) carrying out transactions with funds or other property specified in Article 5 Federal Law from 01/01/2001 , rules of internal control carried out in order to combat the legalization (laundering) of proceeds from crime and the financing of terrorism:

a) Order of the Government of the Russian Federation dated January 1, 2001;

b) Order of the Government of the Russian Federation dated January 1, 2001;

c) Decree of the Government of the Russian Federation.

16. Organizations carrying out transactions with funds or other property in accordance with the rules of internal control are required to document information obtained as a result of the application of these rules and the implementation of internal control programs, and maintain its confidential nature, while the grounds for documenting information are:

a) the confusing or unusual nature of the transaction, which has no obvious economic meaning or obvious legal purpose;

b) the transaction does not comply with the goals of the organization’s activities established by the constituent documents of this organization;

c) identification of repeated transactions or transactions, the nature of which gives reason to believe that the purpose of their implementation is to evade the mandatory control procedures provided for by this Federal Law, other circumstances giving reason to believe that the transactions are carried out for the purpose of legalization (laundering) of income received criminal means, or terrorist financing.

d) only A and B are correct;

e) only A and B are correct;

e) A, B and C are correct.

17. Who supervises the implementation of the Federal Law of 01.01.2001 N 115-FZ “On combating the legalization (laundering) of proceeds from crime and the financing of terrorism”:

a) Rosfinmonitoring;

b) the Prosecutor General of the Russian Federation and the prosecutors subordinate to him;

c) President of the Russian Federation;

d) Government of the Russian Federation.

The condition for completing the test is that only 1 answer option can be correct.

Procedure upon receipt of a request from the Prosecutor's Office:

1. Carefully study the list of required documents;
2. Check the internal control rules for AML/CFT purposes for compliance with applicable law at the time of submission to the Prosecutor's Office;
3. Check with the assistant prosecutor what is meant by a particular document if the request contains vague wording;
4. Study all the responsibilities of organizations or individual entrepreneurs that must be performed in accordance with the law in order to answer all the inspector’s questions;
5. If you have doubts about the correctness of the organization of internal control, in accordance with the requirements of the law, contact a specialist in financial monitoring and AML/CFT.

Specialists from “National Treasure” (METSFM) have participated in numerous inspections conducted by the Prosecutor’s Office and know all the intricacies of this process.

When contacting the center, a specialist:

• will analyze all available documents in the organization or individual entrepreneur;
• if necessary, correct mistakes;
• prepare missing documents;
• will conduct a detailed consultation on the procedure for checking documents by the Prosecutor's Office;
• prepares the responsible employee or manager for typical questions that an inspector may ask;
• if necessary, our specialist can be present with you at the Prosecutor’s Office when providing documents by proxy or represent your interests independently.

Typical mistakes made by organizations and individual entrepreneurs when checking the Prosecutor's Office.

• provision of an incomplete package of documents due to misunderstanding of the wording set out in the requirement.

The same applies to the common misconception that if the organization has no employees other than the director or individual entrepreneur, then there is no need to draw up training documents;

• Not knowing the responsibilities of an organization or individual entrepreneur regarding financial monitoring and AML/CFT leads to the fact that when the inspector interviews the manager and the responsible employee, the latter cannot answer questions correctly about the procedure for performing duties.

• provision of internal control rules for AML/CFT purposes in a version not current as of the date of provision.

We have described only some errors. If you are not 100% sure that you are correctly and fully complying with the requirements of the law, first contact a professional.

Targeted training on AML/CFT, increasing the level of knowledge in the field of financial monitoring and other forms of training: practical recommendations for completing training

SYSLOV P.A.:

Targeted training on AML/CFT, increasing the level of knowledge in the field of financial monitoring and other forms of training:

How and where to get targeted training. practical advice from an expert on financial monitoring, a specialist in educational activities in the field of AML/CFT Pavel Smyslov upon completion of training

(article for jewelry organizations, real estate agencies, leasing and factoring organizations, payment acceptance operators)

Training to combat the legalization (laundering) of proceeds from crime and the financing of terrorism (AML/CFT training) is one of the favorite responsibilities of many organizations that are subject to the requirements of anti-money laundering legislation.

Indeed, for many, targeted training on AML/CFT is always a whole event: you need to come to the training center, listen to an exciting and useful lecture for the whole day and, at the end of it, receive a certificate printed on a beautiful form, which you can then hang on the wall in your office and brag to colleagues: “now I know everything about financial monitoring and AML/CFT!”

However, as the practice of the author of this article shows, who is a lecturer of targeted briefings and raising the level of knowledge both in the Interregional Training and Consulting Legal Center for Financial Monitoring, which he founded, and in other partner training centers, which regularly invite him with pleasure to give lectures, training is still a very weak link in the internal control system for AML/CFT in organizations and entrepreneurs who do not fully fulfill the responsibilities assigned to them by the legislator in terms of requirements for training and education of personnel.

The regulatory framework governing the issues of training is the Order of Rosfinmonitoring dated 03.08.2010 No. 203 “On approval of the regulations on training and education requirements personnel of organizations carrying out transactions with funds or other property, in order to combat the legalization (laundering) of proceeds from crime and the financing of terrorism” (colloquially referred to as “203 Order of Rosifnmonitoring”). According to the established tradition of the author, we will talk to you about responsibilities in the field of financial monitoring not with quotes from regulations, which you can read on your own, without our help, but with your own in simple words, highlighting only the main and most important points.

To begin with, let's define who should undergo targeted training on AML/CFT, increasing the level of knowledge and other forms of training on financial monitoring in organizations and entrepreneurs.

So, the following employees are required to undergo training on combating the legalization (laundering) of proceeds from crime and the financing of terrorism:

a) the head of the organization;

b) head of a branch of the organization;

c) deputy head of the organization (branch), in accordance with his official duties, supervising the organization and implementation of internal control in order to combat the legalization (laundering) of proceeds from crime and the financing of terrorism;

d) a special official of the organization (branch), responsible for compliance with the rules of internal control in order to combat legalization (laundering) of proceeds from crime and the financing of terrorism and programs for its implementation (in simple words - a special official);

d) Chief Accountant(accountant) of an organization (branch), if there is a position on the staff of the organization or branch, or an employee performing the functions of maintaining accounting;

f) the head of the legal department of the organization (branch) or the lawyer of the organization (if any);

g) employees of the internal control service of the organization (branch), if available;

h) other employees of the organization (branch) at the discretion of the head of the organization and taking into account the specifics of the activities of the organization (branch) and its clients.

Thus, it is easy to see that the range of employees undergoing AML/CFT training is very wide and is not limited only to a special official, as many organizations and entrepreneurs think.

Most companies at least have CEO, chief accountant, lawyer, special AML/CFT officer - all of them are required to undergo training in Rosfinmonitoring, incl. and targeted training in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism.

It is very important to note that the head of the organization must approve the list of employees who must undergo mandatory AML/CFT training. Supervisory authorities almost always request this document during an inspection, and at the same time ask to show them your staffing schedule. Staffing table They check not for the purpose of curiosity about the sizes official salaries, as some readers might think, but to check whether all employees of your organization required to undergo training by law have completed it.

Let's now look at the forms, frequency and timing of AML/CFT training.

Conventionally, training in the field of financial monitoring can be divided into two groups: external and internal.

To external forms of training We include targeted training on AML/CFT and increasing the level of knowledge in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism.

To internal forms of training on combating money laundering and the financing of terrorism include introductory and additional briefings.

External forms of training are carried out by specialized training centers that are partners of the International Training and Methodological Center for Financial Monitoring (ITMCFM), which was established by the Federal Service for Financial Monitoring. One of the well-known training centers that provide targeted training on AML/CFT and increase the level of knowledge is the Interregional Training and Consulting Legal Center for Financial Monitoring (ITMCF), established by the author of this article and headed by his talented sister Serafima Aleksandrovna Smyslova. There are other training centers that are partners of ITMCFM.

What is targeted AML/CFT training? Targeted training is the acquisition by employees of organizations of the basic knowledge necessary for them to comply with the legislation of the Russian Federation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism, as well as the formation and improvement of the internal control system of organizations, programs for its implementation and other organizational- administrative documents adopted for these purposes. It is this form of training that many organizations and entrepreneurs love so much: you come to a lecture and immerse yourself in interesting, fascinating, important and useful knowledge (unless, of course, the lecturer of the training center is not some kind of bore, but an experienced and practicing AML/CFT specialist, teacher and true master your business). Some people remember with longing the past student years with lectures from the institute, while others remember school desks and bells for breaks. So, the whole day flies by unnoticed, at the end of which the students, based on the results of the lesson, write a test and in a solemn atmosphere receive a certificate of completion of targeted training in AML/CFT. The author of this article, having conducted targeted training on AML/CFT, always at the end of the seminar wishes the listeners health, happiness and all the best, productive use of the acquired knowledge and work in the field of AML/CFT without penalties. A good tradition has also been established at MUKPTsFM: at the end of the AML/CFT seminar, a group photo of the lecturer and the students of the targeted briefing in the field of financial monitoring is taken as a souvenir.

Students undergo targeted instruction once (once in their life). It is important to note that a person planning to perform the functions of a special official undergoes training in the form of targeted instruction only once before the start of such functions.

One-time training in the form of targeted instruction must also be completed by: the head of the organization (branch), the chief accountant (accountant) of the organization (branch) (if there is a position in the organization’s staff) or an employee performing accounting functions in the organization, the head of a legal department or a lawyer organization (if there is a position on the organization's staff) - these employees must undergo one-time training in the form of targeted training on AML/CFT within a year from the date of assignment of the relevant job responsibilities.

We would like to note that some training centers convince students that they are required to undergo external training annually and literally inundate their clients with mailing lists with invitations to study and announcements of various AML/CFT seminars. Meanwhile, Order 203 of Rosfinmonitoring directly states that employees of organizations and entrepreneurs to whom this article is addressed are required to undergo an increase in the level of knowledge on AML/CFT at least once every three years. Therefore, you are not required to attend training on financial monitoring, targeted training on AML/CFT, or increase your level of knowledge at each invitation from the training center. Frequent attendance at lectures is your right, but not your obligation. The author of this article recommends (but does not impose his opinion, as others do) to undergo training at training centers approximately once a year - in order to always be in “legal tone” and know about all the innovations in the rapidly changing legislation in the field of AML/CFT.

And if organizations and entrepreneurs more or less cope with the obligation to undergo external training in combating the legalization of criminal proceeds (and they would still not be able to cope when they are inundated from all sides by training centers with their offers of targeted training services), then with internal forms of training (introductory and additional training on AML/CFT) everything is much sadder. The author of this article, being a consultant to many organizations and individual entrepreneurs on AML/CFT issues, knows firsthand how internal training stalls in them.

Induction training in the organization is carried out by a special official when hiring for positions or to perform the functions specified at the very beginning of our article. Let us remind you that this is a manager, a chief accountant, a lawyer, a special official, and other employees, i.e. all those whom the organization and entrepreneur must include in the list of employees required to undergo training in accordance with the requirements of Order 203 of Rosfinmonitoring.

Induction training is also carried out by a special official to employees during their transfer (temporary transfer) to the above positions or to perform the above functions.

The same employees are also given additional AML/CFT training by a special official. It is carried out at least once a year or in the following cases:

When existing regulatory legal acts of the Russian Federation in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism are changed and new ones enter into force;

When an organization approves new or changes existing internal control rules in order to combat legalization (laundering) of proceeds from crime and the financing of terrorism and programs for its implementation;

When transferring an employee of an organization to another permanent job(temporary work) within the organization in the event that his existing knowledge in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism is not sufficient to comply with the legislation of the Russian Federation on combating the legalization (laundering) of proceeds from crime, and financing of terrorism;

When entrusting an employee with the organization of work performed by the above-mentioned employees of the organization, but not stipulated by the agreement concluded with him employment contract when the performance of such work does not entail a change in the terms of the employment contract concluded with the employee.

It should be noted that introductory and additional briefings are carried out in accordance with the training program for employees of the organization in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism, developed by the organization taking into account the requirements of Rosfinmonitoring.

Supervisory authorities are very fond of checking the training program. Let us remind you that the training program is a mandatory part of the internal control rules for AML/CFT. But we also recommend approving the training program in the form of a separate document. Very often, organizations are faced with demands from inspectors that it is not enough to have an AML/CFT training program only as part of the internal control rules - it must also be approved as an independent document.

The training program being developed should include:

b) studying the rules and programs for the implementation of internal control in the organization when an employee performs official duties, as well as liability measures that can be applied to an employee of the organization for failure to comply with the requirements of regulatory legal acts of the Russian Federation in the field of combating the legalization (laundering) of proceeds from crime, and financing of terrorism and other organizational and administrative documents of the organization adopted for the purpose of organizing and implementing internal control;

c) study of typologies, characteristic patterns and methods of laundering criminal proceeds and financing of terrorism, as well as criteria for identifying and signs of unusual transactions.

If, as a result of targeted instruction and increasing the level of knowledge, students receive beautiful certificates, which, as we have already mentioned, many people like to hang on the wall of their office, collecting a whole collection of them (we hope that if you decide to collect certificates, then all of them will be issued to you by our training center MUKPTsFM), then how to record the facts of additional and introductory training with employees? To do this, we recommend that you keep two journals: one for information about the introductory briefing, the other for information about the additional training. In them you record the surnames, first names, patronymics and positions of the students, the dates of briefings, signatures of employees on completion of the briefing, and in the additional briefing log also the subject (reason) of the training. Do not forget that the special official also conducts internal briefings for himself. Even if you work alone in an organization: you are a director, an accountant, and a special official (a tailor, a carpenter, and a mouse hunter) - you still give yourself such instructions and make entries in journals.

Conducting additional briefings causes great difficulties. If you only do it once a year, then you are doing something wrong. Additional training in order to combat money laundering needs to be carried out much more often, because Russian Federation in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism come out and change very often (sometimes even several times a month). AML/CFT legislation changes so frequently that sometimes you don’t have time to keep up with it all. How not to get lost in the large body of legislation in the field of financial monitoring? Everything is very simple: the author of this article, on a voluntary basis, has been collecting on his website all the news in the field of AML/CFT, incl. concerning the release of new or changes to existing regulations on financial monitoring. The address of this site is known to many organizations and entrepreneurs: In 2016, the site celebrates its tenth anniversary since its founding (we wish it many more years of work for the benefit of organizations and entrepreneurs and for the popularization of AML/CFT legislation). The author of the article also runs a news block on AML/CFT in the popular social network In contact with. Here is the address of this group: https://vk.com/smyslovy

The group is intended for communication on AML/CFT issues and contains hundreds of questions and answers on financial monitoring. In contact with. Here is the address of this group: Follow the site, subscribe to news on

and you will always be aware of what changes have occurred in the AML/CFT area.

We are often asked questions regarding additional training, approximately the following: “we are a jewelry organization, amendments have been made to the Federal Law of August 7, 2001 No. 115-FZ “On Combating the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism” related to banks. Do we need additional training?" “It is necessary,” we answer: “After all, Order 203 of Rosfinmonitoring does not say anything about the fact that additional briefings need to be carried out selectively.” The next popular question regarding additional training in the field of AML/CFT: “how many days are given to conduct training after approvals?”

1. Targeted training on AML/CFT and increasing the level of knowledge can be completed both in the form of face-to-face seminars and in online format (webinars on financial monitoring). However, in our opinion, students of face-to-face training learn the material much more deeply, unlike webinars. Therefore, try to take in-person seminars. The AML/CFT webinar is an option for those who live or work in remote regions and have no opportunity to come to the training center.

2. Seminars on financial monitoring (targeted instruction and increasing the level of knowledge on AML/CFT), to which training centers invite several lecturers during one day (the first two hours of the lesson are taught by the first lecturer, then the second, third, etc.) – as a rule, they turn out to be very chaotic, without a clear sequence of presentation of the material, which negatively affects the quality of the lecture. Listeners risk not hearing important material

(because the first lecturer hopes that the second will complement him, and the second lecturer thinks that the first has already told everything). Sometimes lecturers contradict their positions throughout the day, which only confuses the audience. 3. Be sure to pay attention to the teaching staff of the training center. Sometimes seminars are taught by lecturers who have only superficial knowledge in the field of AML/CFT, who do not know, for example, how to use an organization’s personal account on the Rosfinmonitoring portal in practice, have never submitted reports to Rosfinmonitoring themselves, and gained their knowledge by independently studying regulations in the field AML/CFT or consultations with your more experienced colleagues. One of best options The lecturer is a practicing specialist in the field of financial monitoring, who has gained his knowledge and experience in AML/CFT through many years of work with organizations and entrepreneurs, and has also passed vocational training

as a specialist in educational activities in the field of AML/CFT.

This is what a certificate of an educational specialist looks like

4. Don’t chase cheap, targeted AML/CFT training.

Prices for training and instructions on financial monitoring can vary by even three or more times. It is quite obvious that if training is carried out very cheaply, it means that the training center is saving on something (quite possibly on lecturers, inviting inexperienced specialists), which ultimately can negatively affect the quality of your training. You can receive a certificate of completion of targeted instruction, but not receive the most important thing - knowledge. 5. During the AML/CFT seminar, try to take notes, highlighting the most important points for you. After completing targeted training or increasing your level of knowledge on AML/CFT, be sure to watch it yourself regulations

, which the lecturer told you about.

6. Don’t be shy to ask the lecturer questions. Giving answers to them is the direct responsibility of the lecturer. The AML/CFT seminar should go until your last question. 7. There is an opinion that only industry-specific training is necessary: ​​i.e. separate for jewelers, separate for real estate agencies, separate for leasing companies, etc. In reality, the AML/CFT legislation for all organizations is almost identical. An experienced lecturer and teacher on AML/CFT will conduct the seminar in such a way that you will not experience any discomfort from the fact that, being, for example, a real estate agency, you listened to a lecture as part of a group in which jewelers predominated. An experienced lecturer will not deprive more than one of them of his attention. field of activity

, whose representatives attend training on anti-money laundering and the financing of terrorism.

8. If you have completed training in AML/CFT, but have not been told which reports to Rosfinmonitoring, when and how they are submitted, we recommend that you apply for retraining at another financial monitoring training center. After all, filing reports is the most important responsibility of any organization and entrepreneur working in the field of AML/CFT. Ignorance of these issues is fraught with thousands of fines. High level

The lecturer’s knowledge in matters of submitting reports to Rosfinmonitoring must be documented 9. Handouts (booklets, CDs, AML/CFT brochures, etc.) that some training centers provide you with tend to become outdated over time: legislation and documents change become irrelevant. We recommend that you independently monitor all changes in the AML/CFT area, focusing on current legislation contained in various information and legal databases.

10. Carefully follow the name of the training form that the training center writes to you on the AML/CFT training certificate.

It happens that a student needs to improve their level of knowledge, but the training is framed as targeted training in AML/CFT. Or, conversely, the trainee had to undergo a one-time targeted briefing on financial monitoring, and he was given a certificate of completion of an increase in the level of knowledge. It’s very disappointing to receive comments on these facts later during an inspection.

11. If you have already completed targeted AML/CFT training on behalf of one organization, then you no longer need to undergo it on behalf of another, despite the fact that the training certificate indicates the name of your first organization: let us remind you that the training certificate in the form of targeted instruction, it is personalized and contains your last name, first name and patronymic. 12. Lectures and seminars on AML/CFT by the author of this article, Pavel Aleksandrovich Smyslov, are very popular. He mainly conducts them at the Interregional Training and Consulting Legal Center for Financial Monitoring. But he can also be seen among lecturers and other training centers

– partners of ITMCFM Rosfinmonitoring: students and management of training centers like the lecturer’s simple and engaging manner of talking about complex AML/CFT legislation. He travels a lot and conducts targeted training on AML/CFT throughout the country: from Crimea to the Far East.

We wish you good completion of targeted training and increased knowledge in the field of AML/CFT! You can receive targeted training from the author of this article by signing up for training with him using this link:

Expert in financial monitoring, Ph.D. history Sciences, lawyer Pavel Smyslov

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