AML Training and Awareness

Many firms struggle to deliver training that is effective and engaging. The most common problems include:

1. 1. Training is deprioritised: Fee earning work takes precedence and training is pushed back or delivered in a rushed or incomplete way. Staff may attend sessions but not retain the information because they are distracted by other demands on their time.
   2. Training becomes formulaic: When the same content is delivered in the same format year after year, it becomes a box ticking exercise. Staff disengage because the material feels repetitive and disconnected from their day-to-day responsibilities.
   3. Content is too dense or technical: Presenting complex regulations in long, formal sessions can overwhelm staff, particularly those who do not have a compliance background. If training is not accessible, people will not engage with it properly.
   4. Staff are reluctant to ask questions: A culture where mistakes are criticised rather than treated as learning opportunities can discourage staff from seeking clarification or raising concerns. This leads to surface level compliance where people go through the motions without genuinely understanding what they are doing or why.
   5. Training does not connect to real work: If the examples and scenarios used in training do not reflect the actual situations your staff encounter, the training will not be useful to them. People need to see how AML obligations apply to their specific roles and responsibilities. When training fails in these ways, it does not achieve its purpose. Staff do not develop the knowledge or confidence they need, and your firm remains exposed to compliance failures.
   6. Building an effective training programme: Good training is practical, relevant and designed to be absorbed and applied. It should be seen as an investment in your team and your firm’s compliance capability, not simply a regulatory task to be completed.
   7. Make the content accessible: Break training into manageable sections rather than delivering everything in a single lengthy session. Use clear, straightforward language and avoid unnecessary technical terminology. Provide materials that staff can refer to when they need guidance on a specific task. Where possible, offer training in different formats to suit different learning styles. This might include in person sessions, online modules, written guides or practical walkthroughs.
   8. Use real examples: Training is far more effective when it uses scenarios and examples that reflect the work your staff do. Walk through the steps involved in onboarding a new client, explain how to assess risk in a context that is familiar to your team, and illustrate what suspicious activity might look like in your practice area. If your firm has encountered compliance issues or near misses in the past, these can be valuable teaching tools, provided they are discussed in a constructive and non-judgemental way.
   9. Tailor training to different roles: Not everyone in your firm needs the same level of detail or the same focus. Your Money Laundering Reporting Officer will require in depth knowledge of the legal framework and reporting obligations. Client facing staff need to understand due diligence and risk assessment. Administrative or support staff may need a more general awareness of what to look out for and when to escalate concerns. Tailoring your training ensures that it is relevant to each audience and that people are not overloaded with information that does not apply to their work.
   10. Encourage questions and discussion: Training should not be a one-way delivery of information. Staff should feel able to ask questions, seek clarification and discuss how AML obligations apply in ambiguous or difficult situations. Creating space for this kind of dialogue helps embed understanding and builds confidence.
   11. Keep records: You are required to maintain records of who has received training, when it took place and what topics were covered. This serves as evidence of compliance and helps you identify any gaps, such as new starters who have not yet been trained or staff who have not received refresher training within the required timeframe.
   12. Creating a compliant culture: Training alone will not deliver effective AML compliance. It must be supported by a broader culture in which compliance is valued, resourced and integrated into the way your firm operates.
   13. Leadership sets the tone: Compliance culture starts at the top. If senior leaders treat AML obligations as an administrative burden or delegate them entirely to junior staff, the rest of the firm will follow that lead. Conversely, if leaders take compliance seriously, attend training themselves and allocate adequate resources to the function, staff are far more likely to engage meaningfully. Leaders should communicate regularly about the importance of AML compliance, recognise good practice and make clear that compliance is a shared responsibility across the firm.
   14. Embed compliance in daily operations: AML checks should not be seen as something separate from the work your firm does. They should be integrated into your standard processes for onboarding clients, conducting ongoing reviews and handling transactions. When compliance is built into everyday workflows, it becomes routine rather than an afterthought. Staff are more likely to carry out their responsibilities consistently and to recognise when something does not fit the expected pattern.
   15. Create safe channels for reporting concerns: Staff need to know that they can raise concerns without fear of criticism or reprisal. If someone is uncertain about whether a matter should be reported, they should feel comfortable seeking guidance from your Money Laundering Reporting Officer or another senior colleague. A culture where questions are welcomed and mistakes are treated as opportunities to improve will always be more effective than one where staff are reluctant to speak up.
   16. Recognise and reinforce good behaviour: When staff demonstrate good compliance practices, whether by identifying a red flag, asking a thoughtful question or completing due diligence thoroughly, that behaviour should be acknowledged. Positive reinforcement helps embed the behaviours you want to see and signals that compliance is valued within the firm.
   17. Monitoring and improving your approach: Training is not something you deliver once and then forget about. You should monitor how effective your training is, gather feedback from your team and make improvements over time.
   18. Track participation and knowledge gaps: Keep records of who has completed training and identify any gaps, such as new staff who have not yet been trained or long serving employees who have not received refresher training recently. You should also consider whether your training is achieving its purpose. Are staff able to apply what they have learned? Are they confident in carrying out their responsibilities?
   19. Gather feedback: Ask your team what worked well and what could be improved. Find out whether the training was clear, relevant and useful. Use this feedback to refine your approach and address any areas where understanding remains weak.
   20. Review adherence to policies and procedures: The effectiveness of your training should be reflected in the quality of your compliance outcomes. Review client files, due diligence records and internal reports to assess whether staff are following your policies and procedures correctly. If you identify recurring errors or gaps, this may indicate a need for additional or more targeted training.
   21. Keep training current: Your training programme should be updated regularly to reflect changes in legislation, guidance or the risk environment. If your firm introduces new services, expands into new markets or encounters new types of clients, your training should be adjusted to address the implications. Training materials should also reflect how work is carried out in your firm. If your processes change, your training must be updated to match.