Why Payment Facilitators Need to Train ALL Employees on Anti-Money Laundering

If you’re a registered Payment Facilitator, a sound policy on anti-money laundering is a requirement. You probably have processes to follow as well (and if not, you need to talk with online payment processing consultants at RPY!). While everybody in your C-suite is likely to know these policies and processes inside and out, a question worth asking today is are all your employees aware of signals that could indicate a money laundering concern?

If not, it’s time to bring them up to speed.

With acquirers increasingly requiring a company’s employees to be trained in anti-money laundering, many payment facilitators may find themselves scrambling to both develop and implement a training program. The key to training your employees properly is understanding why everyone–and we mean everyone–must know the signals of attempted money laundering.

Let’s imagine a scenario: the phone rings and your customer support representative answers. On the other end of the line is a savvy fraudster, but your customer support representative has no idea. The fraudster is friendly, but so is your customer support representative–that’s why you hired them. The fraudster and your employee hit it off. The questions on the other end of the line are innocent enough: can they use a PO box instead of a street address? The fraudster is wondering whether your company will report their transactions to a regulatory or taxation authority? The fraudster has a polite request: can your company not send correspondence to its primary business address, please? And the fraudster, to thank your customer support representative for their time and patience, would love to offer a gratuity or favor.

Your Head of Risk or Director of Compliance will immediately understand the implications of fraud and take appropriate action at these signals, but the average entry-level employee might not. This is exactly why the fraudster targeted them. The road to your company accidentally becoming an accomplice to money laundering is paved with acquiescent, well-intentioned employees who simply haven’t been trained to recognize the signals.

Some examples of those low level signals of a money laundering concern can include an instance when it proves difficult to verify the background of a new or prospective merchant; the merchant’s account details are shared with an inactive account; or when the fraudster, after establishing an inappropriately close relationship with your employee, makes a verbal threat when the company inquires about transaction details.

That’s why the new rules coming from acquirers make so much sense, and why it’s worth it for your company to invest in training all your employees in recognizing the signals of a money laundering concern. Fraud can masquerade as a mistake–inconsistencies in the merchant’s presentation of the transaction, for example. It may appear as a personality quirk on the part of the merchant’s: over-justification of errors encountered in connection with a transaction. Fraud can even show up as bad luck or disadvantage, in the form of a disconnected phone line.

And maybe your average employee would recognize the high-level signals: a merchant nosy about the internal systems of the company, a merchant who provides false or unreliable information, or a one whose bad reputation follows them around. But a smart fraudster is going to start small and subtle, and with newer employees.

So, trust the acquirers and their new requirements. They’ve got your best interest in mind. And don’t think you have to do it all yourself. The right consultant can guide your team into knowing all the signals to avoid money laundering.