Anti-Money Laundering continues to be a growing global concern as the expansion of AML regulations continues around the globe and high-profile cases appear in the news. As money-launderers get more sophisticated with new ways of laundering dirty money, such as cryptocurrency, it’s ever more important to ensure employees in regulated sectors get the very latest AML training.
With the consequences for failure meaning large fines, or even jail, AML compliance needs to be much more than a tick-box exercise. To combat this AML legal experts, law firm Erling Grimstad, have teamed up with gamification experts Attensi to create a new interactive app which provides anti-money laundering and counter-terrorist financing training.
The Fintech Times caught up with the firm’s managing director, Erling Grimstad, to find out more:
Why did you decide on a gamified training solution to counteract money-laundering?
In the period 2016-2018 there were new regulations implemented from the EU. 1000s of employees in obliged entities needed to be trained in anti-money laundering (AML) and we couldn’t see a way to conduct the standardised face-to-face training for all of them, so we needed a new way of digitally delivering this learning. We took part in AML e-learning for employees, but found it to be boring for the employees, so we knew that wasn’t the way forward.
Attensi creates gamified training simulations, which like playing any game are much more interactive and enjoyable – you have to really demonstrate understanding at each stage of the playthrough in order to advance forward and ultimately be certified.
With the AML App we’ve recently launched, employees can be certified within days. But their learning journey doesn’t stop there – after certification, the enjoyable nature of a gamified training process lead staff to continue to train. We have recorded unprecedented engagement numbers.
There continues to be high profile AML cases in the news. Why do you think we are failing to combat money-laundering and what do you think could – or should – be done?
We have been giving advice to all kinds of different obliged entities across the EU and we believe a main reason they fail to comply is the lack of understanding and competence from the people who deal with the clients on the daily basis right up to the board members.
Everyone in the regulated sectors needs to stay abreast of AML and be well-trained in how to spot suspicious activity.
What are the risks around money-laundering for businesses?
If an institution fails to comply with money laundering regulations it can have both a negative corporate and personal implication.
Reputation in the market is at risk for non-compliance, the value of shares usually drop if a company is mentioned in money laundering case. On top of that you can get fined significant amounts if found negligent.
You can also lose your license to operate as a bank or financial institution, and an employee of a company that is involved with money laundering can be investigated by the police as an individual.
What rules and procedures should you put in place?
Training is a vital part of the protection of the entire organisation because there is a legal framework and specific requirements to which you must comply.
You must have a robust anti-money laundering policy and understand any weakness in your organisation, conduct risk assessments and build policies to inform all employees to protect the company, with good internal controls and stay abreast of AML regulations at all times.
You must give employees enough information to understand who is responsible for how to onboard and offboard a customer and what is their obligation within the identity verification process with clients.
How does this AML app create a ‘compliance culture’ where people continuously think about the risks?
The impact of the AML app is that it highlights indicators of suspicious activity.
Attensi has created a lot of different interactions to prevent it from just being a tick-box exercise and something people want to practice and get better at – it’s an enjoyable learning simulation that encourages players to repeat modules until they master the topic, or even beat their colleagues!
For example, the answers change every time you play through and so you must understand to progress.
The dialogue changes throughout the game depending on what you answer, and you need to answer correctly in different circumstances.
What’s interesting is that after people have continued to use it, they get better and achieve a higher score – almost like a competition – so they repeat the training for enjoyment and interest rather than a classroom where you attend just to get your qualification.
Senior management can receive reports outlining the results from training sessions for the employees, so they can also identify where their weak points are and can dial up their own training or internal processes.
How do you know the App helps protect organisations from criminal activity?
The app uses practical examples and ethical dilemmas that you have to solve. The player is in a position where they have to make a choice. You are trained in different situational dilemmas such as how to speak to clients and colleagues and be compliant with AML regulations.
Also, we factor in trends and patterns used by real criminals. By using anonymous AML examples, they learn through storytelling scenarios that feel real.
How regularly is the app updated?
We track changes in the regulations and practices from the FSA’s then we identify and implement the most common compliance needs before addressing it with Attensi who design it into the in-app play, updating any necessary modules.
Do you think lawmakers will add more regulations and increase pressure on the financial sector?
Regulation is rising, resulting in more and more requests from clients who wish to include their own content and features, making the app bespoke their needs.
We can provide the app in their branding and add in the back-office function to include local legislation, meeting the need for compliance in their organisation.
What next for gamified training in financial and professional services?
At the moment we are focusing on developing the in-play dialogues, as these scenarios are the most motivating and practical side of a gamified simulation app.
