What is ComplyTrainer?

ComplyTrainer is Complyport’s proprietary online training system which, while part of the ComplyTracker system, can be subscribed to separately (on an individual to firm wide basis, and for one to several courses) to meet your firm’s (or your individual) training requirements. ComplyTrainer provides and efficient and cost effective method of delivering training to employees, providing them with the knowledge needed to understand their personal and professional duties to protect both themselves and the firm they work for.

Training is often required to demonstrate compliance with UK law (outside of FCA rules); in particular when considering duties under Money Laundering regulations. The delivery of training can be used as a defence if a firm faces prosecution under certain UK laws (under the Bribery Act for example), and is an important tool for firms when considering their duty to employ competent and knowledgeable staff under FCA rules.

How does it work?

The training is online, and can be accessed via an internet link 24 hours a day to allow easy scheduling. Training is accessible via mobile devices, and is convenient and accessible. Every course is broken down into relevant sections, building knowledge and highlighting salient facts and providing relevant examples. Once each course section is completed you will be provided with a series of questions which will unlock the next section. On completion of each course, you will receive a confirmation email. If you subscribe to ComplyTracker, information on training completed is stored and can be swiftly used to evidence ongoing compliance under ‘Training and Competence’.

Courses are highlighted and individuals can use the ‘progress tab’ see which courses they need to do and which you have completed along with their completion certificates and scores. Courses do not need to be completed in one go, and the system has full flexibility in setting training (i.e. courses can be set for any frequency, and at different times). The system will log which sections have been completed and will allow you to return to the start of the last unlocked section when you return to your training.

For those in control of training needs within the firm, you can easily access details of training completed, training overdue in an handy to use screen in order to track progress and follow up where individuals may not be completing training in a timely fashion. Firms should keep a log of all the training employees receive, and this is built into ComplyTrainer. An up-to-date training log also demonstrates that your business is giving its staff the training they need if challenged by regulators or law enforcement agencies.

Training Courses

Anti-bribery

This is an interactive session designed to staff at all levels on the UK Bribery Act 2010 and other anti-bribery legislation, and the importance of conducting business in a non-corrupt way. It can help provide a defence to the corporate offence of failing to prevent bribery. The Bribery Act 2010 creates a new offence under section 7 which can be committed by commercial organisations which fail to prevent persons associated with them from bribing another person on their behalf.

An organisation that can prove it has adequate procedures in place to prevent persons associated with it from bribing will have a defence to the section 7 offence. Companies or individuals that breach legislation will face criminal penalties, including possible unlimited fines. It should be noted that Directors and employees also face possible jail sentences of up to ten years and those companies under the spotlight may well find that profits, business opportunities, reputation, and public trust could all be lost (as well as creating a lot of extra work and costs for senior management).

The Bribery Act 2010 makes the UK’s anti-bribery regime one of the strictest in the world.

Anti-Money Laundering

This course is intended to familiarise employees with the principle concepts of money laundering (placement, layering, integration) and the laws that make it a crime. It provides an overview of key issues and develops an understanding of the legislation and high level FCA rules that apply to those staff whose responsibilities require a firm understanding of what goes into detecting, preventing, and reporting money laundering and financial crimes.

Under UK AML legislation firms are responsible for ensuring employees are aware of the laws covering money laundering. In particular, employees who deal with customers (or find themselves at risk of being involved in money laundering) should receive regular training to make sure your firms complies with the regulations.

As a minimum, training should include being able to recognise suspicious transactions and what to do if they identify them. Our training explains the penalties for committing offences under the Money Laundering Regulations and related legislation (such as the Proceeds of Crime Act).

Market Abuse

Tackling market abuse continues to be a strategic priority for the FCA, and central to their objectives. Further to this, new EU legislation will continue to bring this issue into the spotlight, whilst ongoing court cases against FX traders and large firms for ‘fixing’ rates reflect poorly on the industry as a whole. Market Abuse is one of the most serious issues facing financial services organisations. This course explains concepts and issues such as insider dealing and market manipulation take place, and provides concrete examples of how individuals should react in given situations.

In order for the financial markets to operate fairly, efficiently and to be transparent, all participants have to behave in a way that doesn’t upset or influence the value of markets in a way that is ‘false’, by misusing information they have been given or by fraud. Our training can assist individual employees and senior management in delivering the training needed to educate staff and avoid high profile public court cases.

Approved Persons

The responsibilities of an Approved Person under the regulatory regime are not to be taken lightly, and the FCA continues to take action against individuals who fall short of the requirements with individual fines and bans from the industry. High profile cases highlighting the extreme measures the FCA will take (including banning an individual from avoiding paying train fares) should be a warning for all those who are likely to need FCA approval and to those currently approved. A sound working knowledge of the Statements of Principle and the Code of Practice for Approved persons is essential for such individuals, and this course provides such an overview.

Treating Customers Fairly (TCF)

The course explains the position of TCF within principles-based regulation, and the key principles underpinning the concept of TCF.

Treating Customers Fairly, and particularly the six TCF outcomes, is at the heart of the Financial Conduct Authority’s (FCA) objectives, and is enshrined within the eleven ‘Principles for Business’ (PRIN) set by the FCA which are the fundamental obligations of firms under the regulatory system. The FCA have promoted TCF for several years, and firms should have implemented policies and procedures to enshrine TCF as part of its conduct and culture (And have the MI to evidence this). A firm must pay due regard to the interests of its customers and treat them fairly, and the FCA expects senior management to provide demonstrable evidence of their commitment to this shared value.

Compliance Overview

All firms must conduct business with due skill, care and diligence and the FCA expect senior management of firms to ensure they organise and control their affairs responsibly and effectively. Overall responsibility for compliance and risk management is in the hands of those controlling the business, and those in governing position and senior management positions as well as compliance staff should understand the role of compliance, standards expected by the FCA and the legislation and rules that applies. Nobody wants to be discussing unfamiliar legislation or concepts face to face with FCA staff, or be challenged over their lack of technical knowledge or competence.

This short course provides a brief overview of the legislation, role of the FCA and objectives, alongside a high level summary of the role of the compliance department and should be part of a firm’s training toolkit.