Targeting learning and development to address future financial crime

Financial crime is evolving fast, as rapid digitalisation creates opportunities for cybercrime, fraud and money laundering. Bad actors are increasingly using generative artificial intelligence (GenAI) for deepfakes, phishing and data hacks. 

A stream of new regulations puts pressure on financial services organisations to keep up with complex requirements on sanctions for anti-bribery and corruption, anti-money laundering and tax evasion. These include the UK’s Economic Crime and Corporate Transparency Act (ECCTA), the EU-level Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), guidance from Financial Action Task Force (FATF) on payment transparency and high-risk jurisdictions. As green finance grows, there is an increasing risk of environmental fraud, scams and greenwashing. 

A global financial services organisation wanted to create a culture that adapts to this constantly changing environment. It was concerned that learning and development was seen as a compliance exercise that failed to sufficiently engage its people – or educate on the necessary behaviours to drive a strong risk management culture.  

Learning content was often generic and highly factual, focussing on knowledge recall – which could lead to skills gaps and lack of awareness of emerging threats. Training was also similar from year to year, which was not just repetitive, but was also insufficiently tailored to individuals’ skills levels, business area or seniority. Additionally, learning tended to be a one-off annual exercise, rather than a continuous process that reflects a dynamic financial crime environment.   

This presented an exciting opportunity to rethink the learning content and design, to make it more engaging, personalised and relevant, enhancing both technical and “soft” skills/ behaviours for approximately 60,000 employees in roles with exposure to financial crime risk, dealing with customers who may be associated with money laundering, fraud or other illicit behaviour. 

As Savvas Koufou, EY Global Learning Managed Services Leader, observed, “Financial crime compliance can be a relatively dry topic when focussed on policy and procedures, where learners complete the course and return to their jobs without really considering the real-life implications of what they have studied. We felt strongly that more engaging content, using tailored scenarios and case studies that mirrored people’s daily challenges, could move the dial, developing both skills and curiosity.”

Finally, we performed a thorough thematic analysis of the qualitative data (from interviews and focus groups), along with statistical analysis for the survey and external data. We were careful to consider the perspectives of individuals, functions and regions, as well as leading practices within and outside the organisation.  

Rather than just assessing learning needs, the EY teams collaborated closely with the client’s learning team to help shape the high-level architecture for the future programme. This included the structure of digital learning solutions, implementation plan and business case, paving the way for detailed design and implementation.  

Taking learning and development to the next level 

The EY team’s analysis helped clarify a vision for financial crime learning, as well as identify areas for improvement in the organisation’s existing learning programme. Almost all stakeholders highlighted the need for a stronger risk and anti-financial crime culture and a consistent “tone from the top” to signal why learning is so important, by outlining the human components of financial crime. Soft skills – such as curiosity, agility and communication – were also given the same importance as technical anti-financial crime skills. For example, “critical thinking” was identified as the key skills gap for those working in high-risk roles, described as “the ability to apply critical thought and judgement to a situation, ask questions and join the dots”.  

Four key recommendations 

The following recommendations were proposed to the organisation, then tested in an interactive workshop, for group agreement on next steps:  

1. Forge an anti-financial crime culture 

Change behaviours and mindsets by advancing learning from a “tick box exercise” to a wider understanding of the human impact of financial crime, i.e. what “getting it wrong” means to customers, the organisation and to broader society. Learning should also clarify the behaviours that reinforce a strong financial crime culture, so learners can understand how to apply their knowledge to their day-to-day roles. By encouraging continuous learning, employees can develop their skills and perform their role to the highest standard, to safeguard customers and the organisation.  

2. Develop behavioural skills that support effective risk management 

Focus on soft skills such as critical thinking, communication and strategic decision making, to increase risk awareness, collaboration and curiosity. One of the organisation’s senior executives commented that, “There is a need for employees to think out-of-the-box when dealing with a customer and to think critically about potential risks, even when these aren't immediately apparent.” By creating a safe environment, via scenarios and role play, learners can see the impact of their decision-making and behaviours. 

3. Personalise learning and development 

Tailor learning to the individual, to make it highly relevant, enabling employees exposed to higher risk situations to better understand and anticipate specific customer risks. Using latest technologies to offer digital learning solutions, to provide adaptive pathways, enabling learners to complete training tailored to their capability level. 

4. Focus on emerging trends in financial service industry 

Ensure that learning covers future knowledge related to digitisation, cybercrime, cryptocurrency, environmental crime, AI, geopolitics and sanctions. Provide regular updates on the latest developments in financial crime and compliance, delivered by both internal and external professionals. A mix of micro learning, high-impact videos, documentaries, campaigns and ‘nudge communications’ (short reminders of key concepts), can reinforce knowledge and maintain attention on anti-financial crime efforts throughout the year.

As a result of this LNA, the organisation has built a robust, future-fit learning programme. The future skills blueprint report identified emerging financial crime trends, 12 critical technical and human skills needed to mitigate risks, and skill proficiency levels required for different job types. This helps to address skills gaps and anticipate tomorrow’s financial crime threats. 

There’s a renewed sense of momentum to embed an anti-financial crime culture, widening the learning and development focus from knowledge to awareness and curiosity, or as one organisation executive put it, “The big thing is making people engage in their learning and understand why they’re learning. We should use emotional and powerful stories about things like human rights abuses to highlight the societal importance of managing financial crime.” 

The refreshed adaptive digital learning solution is designed to optimise learning time, whilst targeting capability gaps and areas of risk. It is also set to usher in a new level of continuous improvement, with enhanced management information pinpointing key financial crime challenges, potential risk at an individual, business unit and regional level and specific to learner needs. Rather than focussing on a single, annual test, the emphasis is now on acquiring new knowledge and capabilities throughout the year. The organisation’s customers should also benefit, by engaging with informed colleagues who are aware of evolving financial crime risks and how to best address them.  

According to Savvas Koufou, EY Global Learning, Managed Services Leader, “With the understanding they’ve gained from this learning needs analysis, the organisation is building the skills and the culture to face the future, and to keep one step ahead of the threat of financial crime.”  

Thanks to Elizabeth McLeod, Director, Financial Services, Learning Services, Ernst & Young LLP, for her valuable contribution to this project and case study.