Final Program Proposal - Sabrina Creighton

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Training Program Proposal: New Hire Training for Complex Investigations Unit

Sabrina Creighton – Principal

AML University Training Team

Problem Statement
There is a performance gap in the Complex Investigations Unit (CIU) between the
expected handling of customer-based alerts and actual handling. For each customer-
based alert, an investigator must review the alert documentation and then perform a
thorough investigation. For those that must be filed, there is a significant delay between
the generation of the alert and when the Suspicious Activity Report (SAR) is filed with
the appropriate government agency. Historically, this group has conducted training as a
side-by-side, and the training team has not owned this program.

Needs Analysis
A needs assessment was conducted in accordance with our Training Needs
Assessment process. We identified the following opportunities:

 The current training model used by this group is inconsistent from desk to desk,
and from site to site.
 Performance is inconsistent across the investigators in the department
 Because this is a production-based environment, the “trainer” struggles to
complete assigned work, so they may speed through training.
 The inconsistency in training leaves investigators with unanswered questions or
feeling unsure about steps in the process, which causes investigators to work
slowly through alerts.

In addition, a survey was conducted with fifteen (15) associates that had been both
learners and teachers in the current program. This two-part survey was intended to
collect information about how the current program operated, the experience these
associate had as learners, and the learner experiences they observed as teachers. Part
1 and Part 2 of the survey were delivered separately, 1 week apart. Survey participants
were advised that this was a 2-part survey, but not the context of each part. The main
purpose of evaluating the existing program was to gain knowledge about whether it has
achieved or failed its objectives, and what we should consider in attempting to build a
better program.
What the results confirmed for me was that the trainer is operating in multiple roles at
one time. They don’t feel that they have adequate time or resources to create training
and they feel pulled in many directions while training someone. This seems to be

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disheartening to the trainers since most of them really want to be helpful in this capacity.
From the learner’s perspective, they don’t feel that they are being taught the whole
picture, that training content isn’t teaching them the “why”, and that they are just being
walked through procedures. Add that to an “open-air” training experience, and the
learner hasn’t been put in a position to really learn.

Training Program Proposed


I propose a formal New Hire Training Program for the CIU to be created by the AML
Training Team. The training program would include a mandatory 3-week program for all
new hire associates. This 3-week program would include an official AML Onboarding,
Instructor-Led AML Theory courses, department-specific courses, as well as on-the-job
training. The program will also incorporate other types of content including eLearning
resources, microlearning, reference guides, and infographics. This training program will
also focus on how the learner can successfully transfer the knowledge from training to
their job performance.

Benefits of this Proposed Training Program


Ensuring that our associates have an optimal onboarding experience into our
organization is integral to their ongoing success. In a production-based environment, it
is key for associates to be able to work with speed as well as accuracy. We want to
foster a culture of support and trust among our associates. By providing this training
program, associates will have the opportunity to build foundational AML knowledge,
have structured training to do their jobs, and have a nesting period where they can do
their work in a supportive environment prior to being transferred to the floor to work
independently. We fully believe that this program will set them up for success, and on a
path to continue to grow as investigators.

Goal for this Program


The goal of the New Hire Training Program for the Complex Investigations Unit
module is to help newly-hired associates feel comfortable in the workplace, gain
valuable information on practices that help them become viable resources for the
department, and to help them start building skills that will allow them to produce and
contribute to the department.

Program Evaluation
I will use both formative and summative evaluation techniques to evaluate the outcome
of this program. Using both types of evaluations will provide opportunities to evaluate
the program during its development and implementation, and improve the program as

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needed after launch for future learners. The evaluation questions will follow the AML
Training team’s established Evaluation Process guidelines that are being used by all our
programs. After collecting and analyzing the data from the four levels I will present the
results to my stakeholders. Reviewing the results with my stakeholders will give them
the information they need to determine if the training was an effective intervention. It
closes the loop on the initial program proposal by providing outcome data that will either
support the initial program objectives and assumptions, or indicate that additional
interventions are necessary to address the issue; in either case, I will work with
stakeholders to identify next steps to move forward based on the results.

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