Payments Specific Anti-Money Laundering & Counter-Terrorist Financing (Combatting Financial Crime)
AML training built for UK payment and e-money institutions. Real payments scenarios, from merchant onboarding to transaction laundering, mapped to the MLR 2017, POCA 2002, the Terrorism Act 2000, relevant PSR/EMR requirements, and JMLSG Part I and applicable sectoral and specialist guidance.
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Request a demoWhy do payments firms need their own AML training?
Payments firms move money fast, at scale, and often without ever meeting the customer. That makes them a target. Criminals exploit merchant accounts, e-money wallets, agent networks and card rails to place and layer illicit funds. Generic AML training rarely reflects how this looks day to day in a PI or EMI, which is why the FCA expects training to match your firm’s actual risk exposure. This course does exactly that.
Who needs this training?
Under Regulation 24 of the MLR 2017, relevant employees and agents must receive regular training on money laundering, terrorist financing and proliferation financing. In a payments firm that reaches wide: merchant onboarding and underwriting, KYC and client operations, risk and monitoring teams, agent oversight, compliance, the MLRO and senior management. The people best placed to spot laundering are usually the ones handling applications and transactions, not just the specialists.
What does the course cover?
Learners start with the essentials: what money laundering is, its three stages, how terrorist financing differs, and the basics of proliferation financing. From there the content moves into payments-specific risk.
For PIs and EMIs, that means customer and merchant due diligence, beneficial ownership, source of funds, monitoring e-money and wallet activity, agent and distributor risk, and the red flags that signal placement and layering through payment products.
What does the FCA expect?
The FCA expects effective systems and controls, and training that suits each person’s role and risk. The MLRs 2017 requires regular, appropriate training and records of the measures taken. JMLSG guidance also expects firms to assess whether training is effective, rather than merely record attendance. Content grounded in payments scenarios and mapped to JMLSG Part I, and aligned with relevant sectoral guidance (JMLSG Part II Sector 2 for merchant acquiring, Sector 3 for electronic money, and relevant Part III guidance), helps firms evidence effective, sector-specific AML training.
What your team will learn
- Recognise how laundering moves through payment products and merchant accounts
- Apply customer and merchant due diligence on a risk-based basis
- Spot the red flags of transaction laundering and e-money abuse
- Report concerns to the MLRO correctly, without tipping off
What's included
- ~45 min of focused, scenario-based learning
- CPD accredited (CII)
- Built-in quiz with a configurable pass mark
- Reviewed and kept current with UK regulation
- Time-stamped completion records for your audit trail
How it works
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Assign it in seconds
Enrol a team, a role or your whole firm from the CityREPORTS dashboard, with automated reminders that chase completion for you.
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Your team completes it
Learners work through the course at their own pace on any device, finishing with a short assessment that demonstrates understanding.
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Evidence it to the regulator
Every completion is time-stamped and retained, so you can prove the right people did the right training at any moment.
Frequently asked questions
- Who needs AML training in a UK payments firm?
- Under Regulation 24 of the MLR 2017, every employee whose work is relevant to the firm's AML obligations must be trained. In a PI or EMI that includes merchant onboarding, KYC and operations, monitoring and risk, agent oversight, compliance, the MLRO and senior management.
- How is this different from your standard AML course?
- The core principles are the same, but the scenarios, red flags and due diligence examples are drawn from payments. It focuses on merchant accounts, e-money and wallets, agent networks and card rails rather than, say, lending or insurance products.
- Does it cover transaction laundering?
- Yes. Transaction laundering, where illicit sales are processed through a legitimate merchant account, is a core theme, along with bust-out fraud, shell merchants and refund abuse in the acquiring space.
- How often is AML training required?
- The MLR 2017 sets no fixed interval; it requires appropriate, ongoing training. Many firms provide annual refresher training, but the appropriate frequency should reflect the firm's risks, the individual's role and relevant regulatory, business or role changes.
- Is online AML training acceptable to the FCA?
- Yes. Neither the MLR 2017 nor JMLSG prescribes a delivery method. E-learning is acceptable provided it suits the role, builds genuine understanding, and is assessed and recorded.
- What records must firms keep?
- Records showing who completed the training, when, and on which version. Time-stamped completion records, not simple attendance logs, are what the FCA expects to see, retained for at least five years. Many firms retain these records for at least five years under their internal retention policies.
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