4.4 Training

Financial institutions should provide training to their staff members on a regular basis to ensure that they are, and remain, aware of:

• a. applicable restrictive measures;
• b. the outcome of the restrictive measures exposure assessment; and
• c. policies, procedures and controls to comply with applicable restrictive measures.

Training should be tailored to staff members and their specific role. It should be timely and ad-equate to enable the financial institution to comply with restrictive measures. Within a group this activity can be performed – fully or partially – by the parent company.

Financial institutions should document their training plan and stand ready to demonstrate upon request to their competent authority that their training is adequate and effective.