Staff must be made aware of the need for customers’ personal details and business to be entered correctly in the customer register and the Single Database.
Intermediaries must disseminate notices of negative outcomes of reports among the staff assigned to the unit appointed to exchange information with the UIC. In addition, they may establish direct internal channels of information to the employees who contributed to the preliminary evaluation of the notification.
Support for staff training and dissemination of the discipline as a whole can be provided by the relevant trade associations and other external organizations with initiatives aimed at exploring the legislation in greater depth, studying its application and clearly and effectively spreading a knowledge of it.
3.3 Controls on the actions of employees and collaborators
The competent corporate bodies shall design a structure of controls aimed at preventing or promptly detecting breaches of trust by employees or collaborators.
Repeated transactions triggering the anomaly indicators are to be recorded by individual operating unit or working area.
Possible anomalies connected with the assiduous and unjustified presence on company premises of the persons responsible for strategic sectors or with a standard of living entirely inconsistent with the income these persons earn must be controlled for.
Appropriate controls must be established where accounts are transferred to another branch of the same intermediary on the occasion of transfers of employees or collaborators. Where customers are acquired in connection with the hiring of staff or conclusion of collaboration contracts with personnel coming from other intermediaries, a careful and thorough initial examination of the customers acquired must be conducted.
Failure to notify the competent corporate bodies of new and significant negative elements affecting the evaluation of customers is to be considered a breach of faith on the part of employees or collaborators, especially if they perform externally important functions.
It is also necessary to monitor cases where a branch of an intermediary requests the head office for deliveries of cash or shows cash transactions in amounts disproportionate to the presumable needs of the area where the branch is located or the customers it serves.
Intermediaries shall adopt systems enabling them constantly to check the activity carried on by external collaborators, inter alia with a view to detecting any suspicious transactions carried out by their customers, and shall pay attention to the regularity of the behaviour of financial salesmen, insurance agents and other non-payroll collaborators.
3.4 Electronic money