Refresher AML and CTF Training

23 January 2015

As part of its undertaking to FinCEN, FBME Bank has implemented new ‘refresher’ training for employees that reflects its commitment to implementing tight controls at all times. The new training enhances the already strong training and compliance controls of the Bank. The focus is principally on policies dealing with anti money laundering, know-your-customer, counter terrorist financing and economic sanctions.

The training is based on a 46-page advisory booklet. This leads to a test for FBME Bank employees, which poses the right course of action to take in hypothetical circumstances. The course identifies the issues involved and demonstrates how to recognise breaches of the codes. It details the responsibility of the Bank and the separate obligations of all members of staff.

FBME Bank already had strict controls as EY (Ernst and Young) found during its forensic accountancy investigation of the Bank. In its assessments, EY stated: “FBME’s AML (anti-money laundering) policies are in line with the applicable requirements of the (EU and Central Bank of Cyprus) Directives”. However, EY and the Bank’s legal representatives, Hogan Lovells, made recommendations for tightening FBME’s compliance programme, which the Bank has fully adopted. The refresher training reflects this.

At all times, says FBME, the Bank is committed to conducting its business in accordance with all applicable laws and regulations. Compliance is the responsibility of every person at FBME and the refresher training is part of the way in which all members of staff can share this commitment.


Cyprus’ legal and regulatory framework consists of the following main pieces of AML/CTF legislation and regulations:

o The Prevention and Suppression of Money Laundering Activities Law of 2007 to 2013

o The Central Bank of Cyprus’ Directive to Credit Institutions 4th issue (December 2013)

o Regulation 1781/2006 of the European Parliament and of the council of 15 November 2006 on Information on the Payer accompanying Transfers of Funds