Game based AML - training available

The AMLR contains several provisions on training requirements

These are some of the most important training provisions under the new rules, which apply from 10 July 2027:

• AMLR Article 9(2)(a) requires a policy for employee training.
• AMLR Article 12 requires specific, ongoing training programmes tailored to function and risk. The training programme must be documented.
• AMLR Article 13 requires an assessment of individuals’ knowledge and skills before they take up their position, and regularly thereafter.

Article 13 is the provision that requires a knowledge test, meaning that obliged entities must be able to document that individuals have achieved a certain level of competence. This is referred to below as the pass requirement.

The training measures must cover employees or persons in comparable positions, including agents and distributors (Article 12). Depending on the functions they perform, the training requirements also cover contracted consultants and temporary staff, among others.

Those covered by the training measures must take part in specific, ongoing training programmes that help them recognise transactions that may be linked to money laundering or terrorist financing, and instruct them on how to proceed in such cases (Article 12).

Payment institutions and e-money institutions often distribute their services through third parties. Where this is the case, these third parties will be covered by the training requirement.

Board members and senior management must also be educated. The board and management are not specifically mentioned in Article 12, but they must be included in the training programme.

The training programme must be tailored to the functions or activities of the persons concerned and to the money laundering and terrorist financing risks to which the entity is exposed, and must be duly documented (Article 12).

Quality requirements for the AML/CTF training

The training must be specific and linked to the entity’s products, customers, geographies, channels and the individual’s tasks.

Training must be provided upon taking up a position, and on an ongoing basis. It must be updated when there are changes to the regulations, the risk landscape or changes in the internal procedures.

Training must be tailored to role and risk level. Board members, the compliance officer and staff should therefore receive different training.

The training must be documented. The entity must be able to show who completed the training, when, and with what result.

What level of knowledge is required?

The AMLR requires a dedicated training plan that includes both competence and knowledge requirements (pass requirements).

The pass requirement derives from AMLR Article 13, which requires an assessment of each individual’s skills, knowledge and expertise to carry out their functions effectively.

Attending a course only documents attendance, not knowledge.

It is therefore not sufficient to attend a course on the AMLR if participants do not complete tasks that demonstrate they have acquired the knowledge. This is one of the main reasons we developed the AML app, where a course is not approved until the knowledge test has been completed.

The AML app meets most of the training requirements under the AMLR

With the AML app, you complete courses with content tailored to different sectors and obliged entities, whether you are an auditor, accountant, real estate agent, or work in a bank or other financial institution. The training in the AML app is also tailored to the roles and functions mentioned above.

The AML app contains knowledge tests that meet most of the "pass requirements". On completion, the participant’s knowledge is documented. The AML app requires four out of five stars to meet the knowledge requirement for each task.

The AML app should be completed when a person takes up a position or function, and can be used for ongoing training.

Scores are reset at the end of each year. The following year, a new and updated course in the AML app, which gives you the possibility to use the AML-app year after year. The content is updated annually with tasks that reflect regulatory developments.

The AML-app is also updated every year to reflect the risk landscape for the relevant sector, based on information from authorities and findings from inspection reports.

The “Wiki” articles make up the course documentation itself. These articles are updated throughout the year as relevant money laundering regulations, trends and methods emerges. This may include new rules entering into force, findings from inspection reports, or guidance from AMLA to the supervisory authorities.

A subscription to the AML-app includes a draft training plan with recommended modules and tasks tailored to board members and management, customer advisers, persons with specific responsibilities under the regulations, and other staff whose tasks do not include customer due diligence, investigation, reporting or other key obligations.

Using the AML app, where people in different roles are told which parts of the game they need to complete and which knowledge requirements apply, provides training tailored to the various roles and positions in the entity.

In addition to using the AML-app, we recommend that the entity hold internal training sessions to review specific requirements in its updated risk assessment and procedures.

The entity should also discuss the tasks in the AML-app to ensure a good understanding of threats, vulnerabilities and indicators that help identify suspicious circumstances.

The best feedback we receive from users of the AML-app is that they have learned to recognise suspicious circumstances because they practised it in the game, where they were challenged to resolve dialogues (cases).

You can read more about the AML-app on this website.