Let’s be honest. Financial crime awareness training has a really bad reputation. Ask your staff and they’re likely to say that it’s too long, too technical and too repetitive. To compound the problem, this is mandatory training for many organizations so your staff will see the same messages again and again.

Why Does It Have Such a Bad Reputation?

First, there is awful lot of it (and with good reason). There are two main types of financial crime awareness training:

  1. Umbrella courses dealing with a range of financial crimes in a single course.
  2. Specific courses that address a single financial crime, or subset of financial crimes, such as bribery or market abuse.

The financial crime category is expanding every year. A “traditional” list can include subjects such as insider dealing, market abuse, money laundering, terrorist financing, sanctions, fraud, tax evasion and bribery. These topics are now frequently joined by others, such as cybercrime, competition law and modern slavery. As a result, umbrella courses are getting longer and specific courses more numerous.

It’s not surprising that financial crime awareness training continues to be a priority. Financial crime is a significant risk to organizations and their customers. A failure to manage it appropriately (including the provision of suitable training) is costly not only in terms of legal and regulatory action, but also in terms of reputational damage.

PwC’s 2022 Global Economic Crime and Fraud Survey reveals that fraud has grown substantially since the pandemic and that 46% of surveyed organizations have reported experiencing fraud, corruption or other economic crimes in the last 24 months.

Secondly, subject matter experts (SMEs) are pushing length and complexity.

The financial crime subject matter experts (SMEs) within your organization will be sure to do justice to their area of expertise and have their say. This is especially true for those operating in regulated environments. As financial crime continues to grow and become increasingly sophisticated, the range of examples and red flags that SMEs want to include will also grow, thus adding to the length and complexity of the content. This problem is compounded for global organizations that have multiple jurisdictions to cover.

So How Do We Fix It?

Make It Real

Start on an active note and give the learner a sense that they can make a difference and be a positive agent for change. Rather than running through the technical details of each crime, focus on where and how these risks might crystallize in your organization.

For example:

  • Q: When can this happen in our organization?
  • A: Whenever we start a new relationship with a customer, supplier or business partner.
  • Q: What would make you suspicious?
  • A: An individual gives a complex story about their tax residency.

Leave the detailed, technical descriptions of each financial crime for your intranet, pdf factsheets or targeted technical training. Most staff don’t need to know if it’s fraud, tax evasion or money laundering. They just need to understand when something doesn’t look or feel “right.”

These messages can be delivered efficiently and with impact through video. One effective example is to use interviews with people in front-line roles talking about issues they’ve encountered. When the risks sound — and most importantly, feel — real, you can capture learners’ hearts and minds. Once you have their hearts and minds, behavioral change can follow.

Reassess Whether You Really Need an Assessment

The current trend for this type of course moves away from end-of-course assessments. This requires a leap of faith for many, but the basic core messages here are not well suited to multiple choice style testing. Dropping the assessment frees you up to instead deliver the core messages in new ways, such as microlearning, spaced learning or campaigns.

Consider Who Needs to Know What

Financial crime awareness courses tend to be rolled out to all employees, but everyone may not need all of the content. Tailored content can shorten individual seat times and engage learners more effectively. Even knowing that an effort has been made to tailor the content will be appreciated by learners.

There are a number of options here. Test-outs at the start of the course can allow current employees to demonstrate knowledge and to skip content they’ve seen before. The inclusion of test-outs still enables key messages and new material to be delivered in a concise form to those who pass. It doesn’t have to be an “all or nothing” solution.

Role selection filters enable content and scenarios to be tailored to each learner’s role. Nothing loses the goodwill and attention of the learner more than a scenario that they’ll never experience in practice.

More sophisticated adaptive learning approaches can also be used to tailor courses responsively as the learner interacts with the content. But, even if these approaches are not options within your budget, remember that for an awareness level course, it’s the core messages that are important.

Final Thoughts — Focus on the Core Messages

The core messages at the heart of all financial crime awareness courses are about personal responsibility. In general terms, those messages communicate to learners that:

  1. “This is serious.”
  2. “You can make a difference.”
  3. “If you have any concerns, escalate them.”

What is often forgotten is an explanation of what will happen next. Consider taking learners through the process of making a report in order to demystify it. Confidence is vital. Real life examples of “great saves” are attention grabbing and meaningful here too.

Staff must also understand the potential personal consequences of failing to report, especially those who work for regulated organizations. They need to know that they have a personal obligation under law, regulation and policy and that these may include imprisonment and fines. Again, keep it short — they don’t need to know the specific penalties for every crime and in every jurisdiction.

Remember that this is a topic where specialist technical training will be delivered to targeted groups. Clarity over the learning objectives and success criteria for the awareness level training is crucial. It’s time to draw a line in the sand and go back to basics.

It’s a simple message, so keep it simple.

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