Frisk Insights | Cheats | 03
Firstly, a big thank you to everyone who has subscribed to Frisk Insights on LinkedIn. I spent the last week in Cornwall on holiday and this gave me a chance to refuel. In the next three Frisk Insights, I plan to share some cheats to help you succeed in compliance training. Here’s the first of this three-part edition:
Cheat 1: Document how you deliver training using a blended approach. A training policy helps you capture the ways you train people, through flagship and ad-hoc programmes, and importantly – how you track their attendance and completion rates.
What do we mean by blended training? Essentially, it means using different approaches, online and offline, rather than a "one-size-fits-all" delivery method. And, this definition is constantly evolving – now there are so many ways of accessing content.
According to Wikipedia: "Blended learning, also known as technology-mediated instruction, web-enhanced instruction or mixed-mode instruction, is an approach to education that combines online educational materials and opportunities for interaction online with physical place-based classroom methods."
On "training methods and assessment" a blended approach is also mentioned in the Joint Money Laundering Steering Group (JMLSG) Guidance (Part 1):
"There is no single solution when determining how to deliver training; a mix of training techniques may be appropriate. Online learning systems can often provide an adequate solution for many employees, but there will be classes of employees for whom such an approach is not suitable. Focused classroom training for higher-risk or minority areas can be more effective."
Balance is key: for example, Frisk's e-learning packages are awareness focussed, reminding all staff of key points, such as staff offences and reporting protocols, and they help steer staff through role-based scenarios. To cement this knowledge, these higher-risk staff could be invited to share their stories through informal face-to-face training. Compliance staff might do a more formal postgraduate Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) programme.
Centralise records, by integrating your online and offline invitation/reading lists with your learning platform. You might find the previous insights edition on Strategy useful when deciding on a platform.
Cheat 2: Be successful in audits – you need to know the compliance standards, rules and laws inside out. Make sure there are no gaps in training records and be ready to present the evidence: strategy, recently reviewed policies, training records, assessment criterias and slide samples, when it's your turn to be interviewed.
Top tip: Sample some evidence to show that follow-ups are undertaken (e.g. face to face) if someone fails an e-learning module.
Be assertive with auditors. Training must be effective, learners do disengage when they are given pages of checklists to read or the same compliance video to watch year-after-year. Ideally, compliance training should be engaging, role-based, constantly changing and avoid a tick-box approach. There are many ways you can do this (amongst others): humorous carousel slides, puzzles, scenarios, newsletters that highlight changes to policies and game-based e-learning.
Spice it up and work with your staff to choose popular training methods that get results and still demonstrate compliance with the laws and standards that you are responsible for.
Cheat 3: It's so important to stay up to date and as well as enrolling on courses and reading the latest laws and regulations, other media should play a part in your horizon scanning.
Horizon scanning often reminds me that the old scams die hard in FinTech: ID fraud, front businesses, Authorised Push Payment (APP) fraud, get-rich-quick scams, pyramid selling… The criminal use of money mules is ever prevalent. I started writing about the above sixteen years ago. But, as technology advances, AI being used to create deep fakes, for example (voice, video and photo cloning, etc.) and as new payment methods emerge – the criminal takes advantage – the money laundering highways divert and prevention keeps evolving. For example, advising a victim to “first speak to the family member who is asking you for money on WhatsApp” may date very quickly!
When horizon scanning, things I check include:
Government consultations: keep a checklist of the laws you are responsible for and an eye on consultations and guidance. Get involved and subscribe to the guidance notifications (if available).
Search engines: I often search for GDPR Fine, AML/CTF breach, etc. No doubt, someone you follow on social media will tell you as soon as a fine has been issued, too! Instead of checking aggregators, I prefer to do my own surfing on tech and fincrime "News".
Social media: Doom-scrolling through countless posts about award ceremonies, ads and personal milestones never broadened my mind – so I reinvented my feed. I started engaging with L&D professionals and personal development coaches; connected with designers and artists; I followed regulators, government bodies and the police; and sought out compliance people who talk about fincrime and tech as a sideline to their day job and not only to sell a product.
One highlight for me is Elizabeth Boampong. Her keyword tech articles are fantastic and helped me get my head round so many of the emerging payment methods that my clients work with. I enjoy reading her articles and learning more about her journey – one to watch. Definitely worth checking out.
Another favourite is Luke Raven. He writes with humour, captures his investigative experience eloquently and I love the accounts of his digs around the web, weeding out actual criminal enterprises. His "Reddit" posts are some of the best! Reminds me so much of my work as a Risk Manager. This type of information is invaluable.
Lunch and learn: I keep my hand in with hot-topics by organising regular zoom calls with friends who work in compliance. Stay sociable if you are working from home, and reach out to a few of your colleagues for a virtual lunch. You might be surprised with the support you receive.
Webinars/podcasts: I've recently started attending more of these. It’s important to stay connected with a range of L&D and compliance professionals. But, don’t forget to work on your own personal development, too!
OK. That's it for today. In the next two articles, I'll write about Design, Copywriting, Feedback, Big Data, IP Ownership and Being Agile. What else would you add to this list? How do you do Horizon Scanning? What challenges do you face? I'd love to read your views in the comments below.
Oh, and on the topic of horizon scanning, here’s a picture of a marvellous sunset last week in Perranporth, Cornwall! 🙂
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