Rules, Britannia

Citation

(2003), "Rules, Britannia", Industrial and Commercial Training, Vol. 35 No. 7. https://doi.org/10.1108/ict.2003.03735gab.001

Rules, Britannia

Rules, Britannia

In recent years, money laundering has increasingly attracted the attention of legislators and financial-services regulators. In Britain, a wide range of laws relate to money-laundering activities – including the Drugs Trafficking Offences Act 1994, the Prevention of Terrorism Act 2000, the Criminal Justice Acts 1988, 1990, 1993, the Supplementary Money Laundering Regulations 1993, the Proceeds of Crime Act 2002, the Anti-Terrorism Crime and Security Act 2001 and the Financial Services and Markets Act 2000.

All financial institutions must have procedures in place to prevent money laundering. Indeed, directors and senior managers within the financial-services industry face a two-year jail term for failing to meet these responsibilities. One way in which financial institutions help to meet these responsibilities is by ensuring that their staff are well trained in procedures to identify money laundering and report any suspicions without, of course, breaching customer confidentiality.

Britannia Building Society is the second-largest building society in the UK, with 188 branches, more than 3,300 employees and group assets exceeding £19 billion. The society is meeting its responsibilities under these various laws and regulations by keeping staff up to date in anti-money-laundering procedures through a series of e-learning and e-assessment materials which it has commissioned from VEGA Group plc.

Peter Durrant, of VEGA, explained: “We have been working with Britannia Building Society for some time and, indeed, produced some courseware on the subject of money laundering when the subject came to prominence a few years ago. However, following the introduction of the Financial Services and Markets Act 2000 and subsequent regulations, all financial-services organizations had to ensure that their anti-money-laundering training and procedures were not only up to date but also could be validated, and that their staff had reached the required standard.”

Peter Durrant and his VEGA colleagues visited Britannia’s headquarters in Leek, Staffordshire, UK, to discuss a strategy for helping the building society to do just that.

Peter Durrant pointed out: “The anti-money-laundering regulations apply to all customer-facing staff – not only branch staff but also those who talk to customers by telephone, as well as staff based at the customer-support centre (CSC). Naturally, Britannia wanted these new learning materials to be available as soon as possible. Having been briefed in August last year, we were able to ‘go live’ with the new learning materials in about ten weeks.

“We agreed that the resulting training should be delivered on a “business as usual” basis. This not only meant that the delivery of the courseware should cause as little disruption to the learners’ work and schedule, but also that the learning materials needed to run on the society’s existing information-technology infrastructure.”

As a result, VEGA developed the new anti-money-laundering learning materials using Authorware 4 and designed them for monitors displaying 256 colours.

Peter Durrant commented: “To create the maximum impact and effectiveness from the learning materials, VEGA used software called ‘the debabelizer’. This uses colour intelligently, giving a more sophisticated ‘feel’ to the resulting learning materials than traditional, old-style computer-based training graphics. The results surprised and impressed the Britannia staff who, until they experienced these new learning materials, had thought that they were going to get merely an updated version of the old course.”

VEGA built a new, eight-module anti-money-laundering course. The first six modules contain the theory that all branch and CSC-based staff must know and be able to apply. This includes such topics as how money laundering works, what the law says about money laundering, knowing your customer, reporting your suspicions, and the risk of money laundering.

Learners are assessed on their answers to a number of questions within each module. Once learners have successfully completed these assessments, their results are recorded in module seven. At this stage, employees are allowed to attempt the final module, which comprises four case studies. Each learner attempts one of these case studies – selected at random by the system.

Peter Durrant stressed that these case studies, with content provided by specialists within Britannia Building Society, contained scenarios that are much more subtle than merely being faced with some obvious Colombian drug barons with suitcases crammed with cash.

Completing the case study successfully entitles the learner to a printed “pass” certificate. Candidates who fail the case-study test are allowed one further attempt at a different case study but, if they fail again, they are locked out of the system for seven days. During that time they must continue their studies and discuss their progress with their manager before resitting the case-study module.

VEGA produced versions of the anti-money-laundering e-learning courseware – one for Britannia’s branch network and the other for the company’s headquarters.

Peter Durrant explained: “Where Britannia’s branches are concerned, we provided one CD-Rom to the society’s information-technology services staff, known as desktop services. They put the courseware on each branch’s local server, which is linked to every desktop PC. Users sign on, take the course, and their records are sent back to the server. Once a month, these results are up-loaded to the main server located at CSC, so that these results can be shown to the industry’s regulators, as necessary.

“With the system, regulators can review each learner’s records and see proof of their level of competence.”

Under the current regulations, each relevant member of Britannia’s staff not only needs his or her competence in this field certified, but must go through a retraining and re-certification process every two years. Britannia’s policy is that staff are trained on an annual basis.

Originally driven by Britannia’s compliance department, under the direction of Neil Noakes, and with the society’s compliance-policy adviser, Kerry Lymer, as project manager, responsibility for continuing to deliver this courseware has passed to Julie Lovatt, in Britannia’s group training and competence department.

Julie Lovatt commented: “Britannia regards effective anti-money-laundering procedures as a primary objective and critical to protecting business and member risk. Training and reviewing staff knowledge on an ongoing basis are a key factor.

“The society felt that computer-based training (CBT) would provide the right degree of interactivity with the staff to advance knowledge and skills, while introducing a robust record-keeping system. Whereas a number of providers adapt existing off-the-shelf packages, the real benefit of using VEGA to develop this CBT programme was its provision of technical CBT-development expertise while allowing the society to tailor the training materials to reflect real-world processes and procedures accurately.

“Working in partnership with VEGA, we launched the training programme successfully through a full staff-communication programme. This included putting news of money laundering and the new training programme on our intranet site and giving staff the chance to test the CBT as part of a display, as well as running a competition for staff.

“The results – in terms of demonstrable staff competence in this field – are highly encouraging. We now have a training programme and monitoring system in place that can prove to both the industry regulators and our customers that this society is highly competent and trustworthy.”