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Financial crime

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, PSRs and JMLSG Part II.

Duration: ~45 min Accreditation: CPD accredited (CII) Last updated: July 2026 Reviewed by: Margaret Hassett
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Why 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 Money Laundering Regulations 2017, every employee whose work is relevant to the firm’s AML obligations must be trained. 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, and how terrorist financing differs. 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. Under the MLR 2017 training has to build real understanding, not just log attendance, and firms must be able to evidence it. Content grounded in payments scenarios and mapped to JMLSG Part II (Sector 3) helps you demonstrate that effectiveness at supervision.

See our full suite of AML courses

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

  1. 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.

  2. Your team completes it

    Learners work through the course at their own pace on any device, finishing with a short assessment that demonstrates understanding.

  3. 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. The industry standard is at least an annual refresher, with higher-risk roles trained more often and extra training triggered by regulatory change or a change of role.
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.