2 min read
AML staff training: what passes inspection and what does not
An attendance certificate proves nobody learned anything. What gets tested is whether the person facing the customer knows what to do when they see something worth asking about.
Training is the element of an AML framework most often treated as a formality: a deck emailed round, a sheet signed, a file saved. Then inspection arrives, asks one question of the person on reception, and it becomes clear the whole framework never reached the place it was meant to work.
Who gets trained?
Not the compliance team alone — everyone who might see an indicator or take a decision touching one:
- Anyone who opens customer relationships or receives customers
- Anyone who takes payment or issues invoices
- Anyone who approves transactions or signs contracts
- Directors and senior management — the most commonly skipped group
- New joiners before they start, not in next year's session
What has to be covered?
Generic content about money laundering in the world is not enough. Acceptable training is built on your own business risk assessment and answers questions your team actually faces: what obligations apply to us, how we run due diligence on our customers, what indicators are expected in our sector, who we escalate to internally and within what time, and why tipping off is prohibited.
How often?
Training is periodic by nature, and annual is the usual minimum. But periodicity alone is not enough: additional training is called for when legislation changes, after a regulatory finding or audit result, on entering a new activity or market, or when someone is appointed to a sensitive role.
Documentation: what is actually required
A file that holds up contains more than an attendance sheet. It contains enough to reconstruct the event two years later:
- The date, the duration and the delivery method
- The material itself, in the version actually presented
- The attendance list with names and job titles
- A measure of understanding — a short assessment or applied questions, with results
- A follow-up plan for anyone absent or who did not pass
What we see fail at inspection
- Generic material that never mentions the business's activity or its customers
- Training for compliance only, with the front line left out
- Senior management missing from the attendance list
- No measure of understanding, so nothing shows anything landed
- Joiners who arrived after the session and went untrained until the next one
