The Money Laundering Regulations do not say AML training must be annual. Regulation 24 of the Money Laundering Regulations 2017 requires that relevant employees are made aware of the law and are “regularly given training” in how to recognise and deal with money laundering. No interval is specified. Annual training is convention and supervisor expectation, not a statutory deadline. What is a hard legal duty is the second half of Regulation 24: you must maintain a written record of the training given.
At a glance: Nexis CPD offers a £9 CPD-accredited online Anti-Money Laundering course with a verifiable e-certificate on passing — and any three courses cost £18.
Who has to do AML training?
Far more sectors than banking. The Regulations apply to “relevant persons”, which includes:
- Accountants, auditors, tax advisers and insolvency practitioners
- Independent legal professionals
- Estate agents and letting agents (above the rent threshold)
- High value dealers taking large cash payments
- Trust or company service providers
- Cryptoasset exchange and custodian wallet providers
- Casinos, and financial and credit institutions
Within those firms, the duty covers relevant employees — anyone whose work is capable of contributing to identifying or preventing money laundering, or is otherwise relevant to it. That reaches well beyond the compliance team: fee earners, negotiators, bookkeepers and reception staff who onboard clients are commonly in scope. Since a 2022 amendment the duty also extends to certain agents the business uses.
For the underlying offences and obligations, see our guide to what anti-money laundering is.
How often is “regularly”?
The honest answer is that you decide, and you justify it on risk.
In practice most supervised firms train on induction and then refresh annually, because supervisors — HMRC, the FCA, the SRA and the professional accountancy bodies — expect to see a regular cycle and annual is the easiest to evidence. Some low-risk firms run an 18-month or two-year cycle with interim updates. What no firm can defend is training people once at induction and never again.
Two things should trigger training regardless of where you are in the cycle: a change in the law or guidance, and a change in a person’s role that brings them into scope.
What must the training actually cover?
Regulation 24 names two elements, and firms routinely deliver only the second:
- Awareness of the law — the Regulations themselves, the Proceeds of Crime Act 2002 offences, terrorist financing and proliferation financing, and the data protection requirements relevant to implementing the Regulations. That data protection limb is explicit in the text and is the most commonly missed.
- Recognising and dealing with transactions, activities and situations that may relate to money laundering — in other words, red flags, and what to do about them: internal reporting to the MLRO, Suspicious Activity Reports to the NCA, and the tipping-off offence.
The record is a legal requirement in its own right
This is the part firms lose points on at inspection. Regulation 24(1)(b) requires a relevant person to maintain a record in writing of the measures taken, and in particular of the training given to relevant employees and agents.
A defensible record shows, per person: what training was completed, the date, what it covered, and evidence it was actually done rather than merely circulated. An emailed policy with no completion record is not evidence. A dated certificate with a unique reference is.
Every Nexis CPD certificate carries a unique ID and a QR code that can be checked at our verification page — which means your training record is independently checkable by a supervisor rather than resting on your own spreadsheet.
Which courses does a compliance role usually need?
AML rarely sits alone. The same staff are typically caught by two adjacent regimes, and the same Regulation 24 wording explicitly pulls in data protection:
- Anti-Money Laundering (AML) Awareness — the core requirement
- Anti-Bribery Awareness — the Bribery Act 2010 “failure to prevent” offence, where having adequate procedures is the defence
- Data Protection and GDPR Awareness — named in Regulation 24 itself, and unavoidable once you are collecting customer due diligence documents
All three together are £18 rather than £27, because any three courses trigger the pay-for-2-get-3 offer. Add them to the cart and it applies automatically.
Frequently asked questions
Does the law say AML training must be annual?
No. Regulation 24 of the Money Laundering Regulations 2017 requires that relevant employees are regularly given training in how to recognise and deal with money laundering. It does not specify an interval. Annual refresher training is convention and supervisor expectation rather than a statutory deadline, though most supervised firms train annually because it is the easiest cycle to evidence.
Who counts as a relevant employee for AML training?
Anyone whose work is capable of contributing to identifying or preventing money laundering, or is otherwise relevant to it. That reaches well beyond the compliance team and commonly includes fee earners, negotiators, bookkeepers and staff who onboard clients. Since a 2022 amendment the duty also extends to certain agents the business uses.
Do you have to keep a record of AML training?
Yes, and this is a legal requirement in its own right. Regulation 24(1)(b) requires a relevant person to maintain a record in writing of the measures taken, and in particular of the training given to relevant employees and agents. A circulated policy with no completion record is not evidence; a dated certificate with a unique reference is.
What must AML training cover?
Two things. First, awareness of the law: the Money Laundering Regulations, the Proceeds of Crime Act 2002 offences, terrorist and proliferation financing, and the data protection requirements relevant to implementing the Regulations. That data protection element is explicit in Regulation 24 and is the most commonly missed. Second, how to recognise and deal with suspicious transactions, including internal reporting, Suspicious Activity Reports and the tipping-off offence.
Which sectors need AML training?
Far more than banking. The Regulations apply to accountants, auditors, tax advisers and insolvency practitioners, independent legal professionals, estate and letting agents, high value dealers, trust or company service providers, cryptoasset exchange and custodian wallet providers, casinos, and financial and credit institutions.
AML and compliance training
£9 per course. CPD accredited, 100% online, verifiable e-certificate. Pay for 2, get 3 — any 3 courses for £18.
This article is general information, not legal advice. A CPD awareness course is not a regulated qualification and does not by itself discharge a firm’s obligations under the Money Laundering Regulations 2017. Awareness training does not replace firm-specific policies, controls and procedures, a written risk assessment, or the role of a nominated officer or MLRO. Firms should follow their supervisor’s guidance and take specialist advice where required.