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Are AML courses taken at your office?

Question no. 5 from the supervisor
Can you indicate whether you and/or other office employees are following courses dedicated to AML? What is the frequency of this (Article 3 of the AML Supervision Policy Rule 2018) and when did the last AML course take place?

What is mandatory?

Every office 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 and is included in Article 35 of the AML.

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. The standard from Article 35 has been further elaborated in the AML Supervision 2018 policy rule for local deans.


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.
  • recognize 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: always provide training every year and with every policy update. The AML policy should be a dynamic part of every office. Also make sure you always submit proof of participation after every training.

Themed file: fully prepared for the supervisor’s audit

This article is part of a number of articles and downloads that will help you prepare yourself for the supervisor’s visit. This content is based on a supervisor's FAQs during an audit. Do you want to be 100% AML-proof and ready for the supervisor’s visit? Find all FAQs in our Knowledge Centre.

Knowledge centre

Download the ‘100% AML-proof’ checklist