LFIs should ensure that personnel responsible for performing TM and sanctions screening roles receive training that covers key financial crimes risks faced by the institution (such as common ML/TF/PF or sanctions evasion typologies), complex and higher-risk customer and transaction types relevant to TM and sanctions screening processes, applicable legal and regulatory requirements, and internal policies, procedures, and processes. Training should be tailored to each individual’s specific responsibilities and include desktop procedures or instructions for the use of any TM or sanctions screening systems or other technology relevant to the individual’s role.

An LFI’s TM and sanctions screening training should be based on an assessment of the institution’s training needs, incorporated into wider AML/CFT and sanctions training plans and programs, and subject to completion tracking and escalation procedures to ensure timely completion of mandatory training by all relevant personnel. Mandatory training should also be extended to any staff located abroad whose responsibilities cover accounts booked in or activity flowing into, out of, or through the UAE.