Anti-Money Laundering & Counter-Terrorist Financing

Frequently asked questions

Who needs AML training in a UK regulated firm?

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 practice that is broad: client-facing staff, onboarding teams, compliance and risk functions, the MLRO, and senior management.

How often is AML training required in the UK?

The MLR 2017 sets no fixed interval; it requires appropriate, ongoing training for relevant staff. The industry standard is at least an annual refresher, with higher-risk roles trained more often and additional training triggered by regulatory change, internal incidents, or a change of role.

What must AML training cover?

JMLSG guidance indicates training should cover the three stages of money laundering, customer due diligence (CDD) and enhanced due diligence (EDD), politically exposed persons (PEPs), suspicious activity reports (SARs), the tipping-off prohibition, and the firm's own policies. Content must suit the employee's role and risk exposure.

What AML training records must firms keep?

Firms should keep records showing who completed AML training, when, and on which version of the course. Time-stamped completion records — not just attendance logs — are what the FCA expects to see during financial crime supervision, and records should be retained for at least five years.

Does a new joiner need AML training straight away?

JMLSG guidance states that relevant employees should be trained before they begin work, or as soon as reasonably practicable after joining. Firms should not wait until a full induction period is complete for roles that carry immediate money-laundering exposure.

What are the consequences of inadequate AML training?

Failing to train relevant staff is a breach of Regulation 24 of the MLR 2017 and can form part of a wider systems-and-controls failing. The FCA and HMRC can impose substantial financial penalties, and individuals may face personal liability. Several multi-million-pound enforcement actions have cited weak staff awareness and training.

Is online AML training acceptable to the FCA?

Yes. Neither the MLR 2017 nor JMLSG guidance prescribes a delivery method, so e-learning is acceptable provided it suits the employee's role, builds genuine understanding, and is assessed and recorded. The FCA cares about effectiveness and evidence rather than format, so completion data and knowledge checks matter.

How does AML training relate to the MLRO's responsibilities?

The Money Laundering Reporting Officer oversees the firm's AML regime, including ensuring relevant staff are adequately trained under the MLR 2017. The MLRO typically owns the training programme, monitors completion and reports on it to senior management. Effective front-line training ensures suspicions actually reach the MLRO through internal suspicious activity reports.