♦Who Needs What, and When?♦
Who is required to take Anti-Money Laundering and Cybersecurity compliance training? We’re asked that question a lot. If ongoing training for your firm is mandated, it’s simply not enough to train your brokers and APs.
Anti-Money Laundering Training:
NFA-member FCMs and IBs and FINRA-registered Broker-Dealers must provide ongoing training to “appropriate” personnel in areas susceptible to money laundering. This is a broad mandate that includes employees involved in account solicitation, account opening, customer service, order execution, back-office operations, finance and treasury. NFA requires training within 365 days. FINRA requires ongoing training, which most firms administer annually. Ongoing training for SEC-registered RIAs is considered a best practice at this time.
Non-bank residential mortgage lenders and originators are also required to administer ongoing training to appropriate personnel under the Treasury Department’s Bank Secrecy Act.
NFA’s Information Systems Security Programs Interpretative Notice requires all member firms to provide their employees with cybersecurity trainingupon hiring and periodically during their employment. This includes virtually everyone — anyone who uses a computer, has access to the firm’s physical premises or is involved in IT support. Every firm’s Information Systems Security Program must be updated annually, and most member firms provide annual training to coincide with this cycle. Cybersecurity training for FINRA-registered firms is highly recommended.