A Guide to Staff Training

Licensees who are regulated by the Isle of Man Gambling Supervision Commission (the “GSC”) under the Online Gambling Regulations Act 2001 (“OGRA”) are expected to uphold the core principles of ensuring the gambling industry is kept crime-free, protecting the young and those considered at risk, and to ensure player protection through fair services and that players receive their true winnings.

In this regard, the Isle of Man Gambling (Anti Money Laundering and Financing of Terrorism) Code 2019 (“the Code”) sets out the responsibilities and expectations of licensed entities to prevent their operations from being subject to money laundering and terrorist financing risks.

Training bridges the gap between the GSC’s core principles and The Code, giving tangible and real-time examples of why it’s important.

Why should training be provided? 

As well as being a legal obligation – robust training forms the cornerstone of a businesses compliance culture. Evidencing regular compliance training is also a requirement of the Code. Therefore, a register should be kept of all persons to whom training has been provided, the date it was provided and how their knowledge was tested. Additionally, the versions of the training should be kept so that you can evidence to the regulator what was covered.

Who should training be provided to? 

Within the Code, Paragraph 27 covers the requirement for the business to provide education and training to the following persons within the business: -

• All directors and officers
• Any other persons involved in its senior management; and
• Appropriate employees and workers

A good training programme should cover both the regulatory obligations under the various regulations, Acts and Codes, but also have relevance to the businesses own operation processes. Training programmes should form part of employee objectives and businesses should be SMART when setting out its objectives as this provides tangible results to evidence to the regulator that not only are you providing training, but you are able to measure its effectiveness. The acronym (for those who are not familiar) is: 

S – Specific

M – Measurable

A – Achievable

R – Relevant

T – Time-bound

When should training be provided? 

In accordance with the Code, education and training should be delivered at least annually. Additionally, where there have been significant changes to the AML/CFT legislation or your internal policies and procedures then training should be provided as part of the roll out of the new documented procedure. It is also mandatory to provide Anti-Money Laundering, Counter Proliferation Financing & Countering the Financial of Terrorism (“AML/CPF/CFT”) training to new starters as part of their induction process. This will give the Board comfort that all staff have a knowledge and awareness of the ML/PF/TF threats of the business and who to report any potential suspicious activity to.

What should be included? 

The training should include: 

• An overview of the AML/CFT legislation.
• Personal obligations in the AML/CFT legislation.
• Reporting procedures and controls i.e., who is the MLRO or AML/CPF/CFT Compliance Officer, how can they be contacted, what is the internal procedure for reporting suspicion.
• Internal policies and procedures regarding AML/CPF/CFT.
• What to do when handling unusual/suspicious activity.
• Personal liability for failure to report.
• Tipping off.
• New developments, methods, and trends in respect of ML/PF/TF.

Training Top Tips

The following list is our top tips for conducting successful training: -

• Make it fun – people are more likely to remember the content if you keep it interesting. This could be by making it interactive, using videos and animations.
• Make it relevant - utilising relevant case studies or investigations either by jurisdiction or by sector.
• Test the learning – at various stages throughout the training test the learning via a short quiz, arranging keywords with their definitions, even a crossword or word search!
• Finish the training with a quiz/test to evaluate the learning and if the key objectives of the training have been met.
• Set the training so that if someone fails it, you can identify areas of weakness and follow up with additional training on that specific area.

Learn More

Amber Gaming is a specialist gaming consultancy business providing multi-jurisdictional licensing, regulatory compliance advice and professional support to clients across all areas of the gaming industry.

At Amber Gaming, we can provide specialist training (both online and face-to-face) for these roles, to facilitate your professional development in this dynamic and challenging profession, aiding current positions held; or helping you achieve your career aspirations.

If you are interested in learning more or discussing your licensing or training requirements, please feel free to reach out to us via the Contact Us form.