Anti-money laundering (AML) training teaches staff how to recognise transactions and situations that may involve money laundering, terrorist financing or proliferation financing, and what to do about them, including how to report a suspicion. For businesses in the regulated sector it is a legal requirement. Regulation 24 of the Money Laundering Regulations 2017 requires you to make relevant employees, and agents doing the same kind of work, aware of the law, to train them regularly and to keep a written record of the training.
This guide explains who the rule applies to, what it requires, what happens if training is missing, who needs what, what to cover and how often to train.
Which businesses have to provide AML training?
The Money Laundering Regulations 2017 apply to “relevant persons” carrying on business in the UK. They include:
- credit and financial institutions
- auditors, insolvency practitioners, external accountants and tax advisers
- independent legal professionals
- trust or company service providers
- estate agents and letting agents
- high value dealers
- casinos
- art market participants
- cryptoasset exchange providers and custodian wallet providers.
Some of these are only covered above certain thresholds or for certain activities, so check with your supervisor. Depending on your business, that is the FCA, HMRC, the Gambling Commission or a professional body.
The regulations also require you to appoint a nominated officer, often called the money laundering reporting officer, to receive internal reports. Where appropriate to your size and business, you must also appoint a board member or senior manager responsible for compliance and screen relevant employees.
What does regulation 24 require?
Regulation 24 requires you to take appropriate measures to make sure your relevant employees, and any agents whose work is of the same kind, are:
- made aware of the law on money laundering, terrorist financing and proliferation financing, and of the data protection requirements that apply when you carry out the regulations
- regularly given training in how to recognise and deal with transactions, activities or situations that may be related to money laundering, terrorist financing or proliferation financing.
You must keep a written record of the measures you take, and in particular of the training given.
A relevant employee is anyone whose work is relevant to your compliance with the regulations, or could help identify or reduce the risks your business faces, or help prevent or detect money laundering. That usually goes well beyond the compliance team: it includes people who meet clients, take payments, onboard customers or approve transactions.
What is appropriate depends on the nature of your business, its size and the risks it faces. You may also take account of guidance issued by the FCA or by your supervisor and approved by the Treasury.
What happens if staff are not trained?
The consequences fall on the business and on individuals:
- Civil penalties. Under regulation 76, a supervisor can impose a penalty of such amount as it considers appropriate, or publish a statement censuring the business. Officers knowingly concerned in a breach can be penalised too.
- Criminal offence. Under regulation 86, contravening a relevant requirement of the regulations, which include the training duty, is an offence, with up to two years’ imprisonment on indictment.
- Staff themselves. Under section 330 of the Proceeds of Crime Act 2002, someone working in the regulated sector commits an offence if they know or suspect, or have reasonable grounds to know or suspect, that a person is laundering money and do not report it to the nominated officer as soon as practicable. The maximum penalty is five years’ imprisonment. Tipping off someone that a report has been made is also an offence.
That last point is a good reason to train staff well. The test includes “reasonable grounds” to suspect, so people need to know what the warning signs look like in their own work. The Act also links the offence to training: under section 330(7), someone who did not actually know or suspect has a defence if their employer did not give them the training specified for this purpose. That protects the untrained employee, but the gap then sits with the business, which has its own duty to train under regulation 24.
Who needs AML training?
| Who | What they need |
|---|---|
| Client-facing staff | Customer due diligence, the warning signs in your sector, and how and when to report a suspicion to the nominated officer without tipping anyone off. |
| Staff who onboard customers, take payments or process transactions | Identity and ownership checks, unusual payment patterns, third-party and cash payments, and when to stop and escalate. |
| Managers, partners and directors | The firm’s risk assessment, their oversight role, approving higher-risk business and setting the culture. |
| The nominated officer and deputies | In-depth training on assessing internal reports, making suspicious activity reports to the National Crime Agency and keeping records. |
| Agents doing relevant work | The same awareness and recognition training as employees doing that work, as regulation 24 now covers them too. |
A training needs analysis helps you decide who counts as a relevant employee and how much training each role needs, using your business-wide risk assessment as the starting point.
What should AML training cover?
- The law. The main money laundering offences, terrorist and proliferation financing, the regulations and the data protection rules that apply to the information you collect.
- Your risks. The findings of your own risk assessment and the typical risks in your sector.
- Customer due diligence. Identifying and verifying customers and beneficial owners, when enhanced checks apply and what to do when checks cannot be completed.
- Warning signs. Examples from your own work, such as reluctance to provide information, funds from an unexplained source, unusual use of cash, complex ownership structures, payments from third parties and last-minute changes.
- Reporting. How to report to the nominated officer, what happens next and how to avoid tipping off.
- Record keeping. What to record and how long to keep it under your procedures.
- A short assessment. It checks understanding and gives you evidence for your written record.
Generic or tailored training?
Regulation 24 asks for measures appropriate to your business and its risks. A generic course can explain what money laundering is, but it cannot show an estate agent, an accountant and an art dealer the warning signs in their own transactions, or walk staff through your own reporting procedure.
Free resources help. HMRC publishes training films and discussion notes for some of the sectors it supervises, such as estate agency and the art market. Many professional bodies also publish guidance for their members. The most effective training combines this with your own policies, controls and procedures, and with scenarios from your own client base.
Online or face to face?
E-learning suits the awareness and recognition training that every relevant employee needs. It gives everyone the same message on your procedures, can include agents, and records completions and test results for your written record. Scenario-based modules let staff practise spotting warning signs and making internal reports.
Live sessions suit the nominated officer, senior management and teams handling the highest-risk work, where discussing real cases is the point.
How often should AML training be done?
The regulations say training must be given regularly but do not set an interval. We suggest training before someone starts relevant work, an annual refresher, and an update whenever the law, your risk assessment or your procedures change, or when a new risk appears in your sector.
How Capytech helps
We build AML training to order around your own policies, controls and procedures. FastTrack turns your risk assessment, procedures and real scenarios from your sector into a custom e-learning module with a knowledge check, built from your documents in days. Updates are turned round in 48 hours, so the training keeps up when the regulations or your procedures change. Our failure to prevent fraud and anti-bribery guides cover the other economic crime training many firms combine with it.
The Capytech LMS assigns the right training to each role and keeps the written record regulation 24 asks for: who completed what and when, and their test results. Its compliance matrix shows who is valid, due or overdue, and certificates carry renewal dates so refreshers happen on time.
If you are regulated by the FCA, see our page on e-learning for financial services. Our free mandatory training checker shows where AML training sits among your other training duties.
Frequently asked questions
Yes, for businesses in the regulated sector. Regulation 24 of the Money Laundering Regulations 2017 requires them to make relevant employees and agents aware of the law, train them regularly to recognise and deal with suspicious transactions and situations, and keep a written record.
Every relevant employee: anyone whose work affects your compliance or could help identify, prevent or detect money laundering. That usually includes client-facing, onboarding and payments staff, managers and the nominated officer, as well as agents doing the same kind of work.
The regulations require regular training but set no interval. Training before someone starts relevant work, an annual refresher and an update when the law or your procedures change is a sensible pattern.
The law, your own risk assessment, customer due diligence, warning signs from your sector, how to report to the nominated officer without tipping off, record keeping and a short assessment.
The supervisor can impose a financial penalty or publish a censure, and breaching the regulations can be a criminal offence with up to two years’ imprisonment. Untrained staff are also more likely to miss the warning signs they have a personal duty to report.
See your own training as e-learning, free
Send us one document and we will turn it into an interactive demo module, so you can judge the quality before you spend anything.