Are AML courses taken at your office?

What is mandatory?

Every firm that deals with AML is obliged to train employees on the subject of 'AML' at least once every two years. This also applies to partners and supporting positions (e.g. secretaries, accounting team). Office managers dealing with AML and/or compliance officers must take an annual AML course. This is called the AML training obligation.

These rules are designed to provide everyone with sufficient knowledge and to raise awareness about how AML works. It is therefore important that your employees are familiar with it. 

How do you organise an AML training?

The training should ensure that employees:

• Understand the effect and usefulness of AML.
• Are aware of the latest guidelines and the current work process.
• Recognise any unusual transactions, and
• Conduct a Customer Due Diligence properly and completely.

We recommend designing every training session based on internal examples. Adjust the content to the type of employees who follow the training. If the secretariat is trained, zoom in on what these employees find important and what is expected of them. Try avoiding too much legalese and make sure that you provide practical tools, in addition to the necessary theory. As for lawyers, keep in mind that many of them are likely to have difficulty  determining whether a matter falls under AML. Address this need and discuss the criteria. There are plenty of examples from daily practice that you can use.

Our advice is: train with every policy update 

We are frequently asked to advise on AML courses. The supervisor wants you to show how often training sessions take place and with what content. So keep this in mind: provide an internal training every year and with every policy update. The AML policy should be a dynamic part of every firm. Also make sure you always submit proof of participation after every training.