8 tips for making AML training easier
For those working in the UK’s regulated sectors, anti-money laundering (AML) training isn’t just a box-ticking exercise. It’s a regulatory requirement with real-world consequences if not handled correctly.
But with ongoing demands, tight deadlines and ever-evolving risks, how do you ensure anti-money laundering training is not just completed but truly integrated into your daily operations?
In this article, I’ll give you my eight practical tips to help you weave AML training requirements into the rhythm of your business, so your approach feels less like a chore and more like a natural part of working life.
Integration matters
Annual training in AML may satisfy the minimum regulatory requirement. But it rarely changes behaviour on its own. The most common training gaps aren’t due to a lack of materials but rather a disconnect between formal learning and real-life practice. That disconnect leaves businesses exposed — legally, financially, and reputationally.
Making AML training easier means embedding it into your routine. When awareness is part of everyday decisions, everyone wins: your team, your clients, and your regulators.
1. Make AML part of onboarding for new team members
A well-structured onboarding programme is your first opportunity to set expectations. Embedding AML training at this stage signals its importance and aligns new starters with the business’s values and obligations.
You can go further by assigning sector-relevant case studies early in the process, helping staff see how training AML protocols play out in context. These examples prompt discussion and ensure early familiarity with warning signs, escalation routes, and who your Money Laundering Reporting Officer (MLRO) is.
2. Build a culture of continuous learning
Good AML training isn’t a one-off event. It should evolve as risks evolve, especially in high-risk sectors like conveyancing, trust and company services, or advisory work for overseas clients.
Instead of waiting for your annual training window, incorporate short refreshers into regular meetings. These can be quick: a five-minute scenario in a team meeting, a short update in the staff newsletter, or a “what would you do?” poll around the table. The aim is to maintain awareness without overwhelming the team.
3. Use real-world cases to encourage engagement
Real cases make abstract concepts tangible. They spark discussion, reveal blind spots, and encourage critical thinking. Use anonymised or public cases from your own sector to promote learning and highlight consequences. This keeps money laundering training rooted in the risks your team actually faces.
For example:
Accountancy
Between April and September 2023, HMRC fined 21 accountancy businesses and tax advisers for breaches of the Money Laundering Regulations 2017, with total penalties of almost £100,000. These penalties included failures such as inadequate customer due diligence, poor risk assessment, and insufficient AML policies and procedures—common across several accountancy practices.
Legal
The Solicitors Regulation Authority (SRA) issued its maximum fixed penalty of £25,000 to a central London law firm, Mellor & Jackson Ltd, for serious anti-money laundering (AML) breaches. The SRA said that the firm failed to carry out a compliant risk assessment, didn’t have proper AML policies and controls in place, and neglected to train staff adequately between 2017 and 2022. The SRA emphasised that the failures were systemic and prolonged.
Property
HMRC penalised 175 estate and letting agents in the 2022–23 financial year for breaches of anti-money laundering (AML) regulations, issuing £1.6 million in fines. The most common failings included not registering with HMRC, not conducting proper risk assessments, and failing to provide AML training. HMRC warned that non-compliance continues to be a serious problem in the property sector.
4. Tie training to the role
Your fee earners and admin staff face different AML challenges. So their AML training content should reflect those realities.
Tailoring training to roles helps staff apply it. Those dealing with client due diligence should be confident in identifying beneficial owners and understanding source of funds. Partners approving matters should understand the risk scoring framework. And your front desk or reception team should know when to escalate unusual behaviour.
5. Make escalation procedures accessible
Training on the risks alone isn’t enough if staff don’t know what to do when something feels off. That means your escalation procedures need to be crystal clear and easy to follow. Ensure that:
- your MLRO’s contact details are clearly displayed on your internal systems.
- staff know how to make an internal suspicious activity report (SAR).
- the escalation route is reviewed regularly in team meetings or briefings.
If someone only hears the SAR process once a year during training, they’re unlikely to recall it under pressure. Repetition builds familiarity, which builds action.
6. Track and evidence everyone’s training
Under the Money Laundering Regulations 2017, you must not only carry out AML training activities but also keep records. These records should demonstrate what was delivered, when, to whom, and how it was relevant.
This isn’t just for your own peace of mind – regulators expect it. Your documentation should include:
- Records of all staff who completed training
- Any role-specific modules
- Dates of training and refreshers
- Topics covered and materials used
Think about how your systems log and retrieve this data, and whether your process makes it easy to report at short notice. If not, now’s the time to tighten up.
7. Keep up with regulatory & risk changes
Money laundering methods evolve fast. Criminals adapt to new technologies, loopholes and legislation. So should your training.
Review your training AML content at least annually to reflect changes in:
- risk indicators (e.g. around crypto, offshore trusts, or high-risk jurisdictions)
- legislation and guidance (from HMRC, SRA, FCA or other regulators)
- internal policies, such as customer risk assessments or client onboarding procedures
- When new threats emerge, communicate them quickly. You might do this via a short all-staff alert or a feature in your next training session. Either way, you show that training isn’t frozen in time.
8. Create a feedback loop
Training is most effective when it’s two-way. Invite feedback after sessions: what was clear, what was confusing, what needs more focus?
Use this insight to fine-tune your future content. If many staff struggled with source of funds, build this into your next refresher. If some training feels irrelevant to certain roles, adapt it to suit the needs of the group.
This responsive approach not only improves effectiveness but shows staff that their insight matters.
AML training has to live beyond the classroom
It needs to be reflected in conversations, decisions, supervision, and policies. That means shifting the mindset from “training as task” to “training as culture”.
By embedding money laundering training into daily operations – through onboarding, regular refreshers, role-specific content, and real-world scenarios – you protect your clients, your team, and your business.
Not just because the regulations demand it. But because the risks are real.
- Integration matters
- 1. Make AML part of onboarding for new team members
- 2. Build a culture of continuous learning
- 3. Use real-world cases to encourage engagement
- 4. Tie training to the role
- 5. Make escalation procedures accessible
- 6. Track and evidence everyone’s training
- 7. Keep up with regulatory & risk changes
- 8. Create a feedback loop
- AML training has to live beyond the classroom