AML training — the duty that reaches your agents
Article 12 of the AMLR is short, and it contains two words that reshape most training programmes: agents and distributors. Regulation (EU) 2024/1624 requires obliged entities to ensure that employees or persons in comparable positions whose function so requires — including their agents and distributors — are aware of the requirements, and to put them through specific, ongoing training programmes that are duly documented. For a payment or e-money institution with a distribution network, that is a substantial extension of scope.
1. Awareness: four things people must know
The first paragraph is an awareness duty rather than a training duty, and it names its content. The relevant people must be aware of:
- the requirements arising from the Regulation;
- the requirements arising from Regulation (EU) 2023/1113 — the rules on information accompanying transfers of funds and certain crypto-assets;
- any administrative act issued by any supervisor; and
- the business-wide risk assessment and the internal policies, procedures and controls in place — including in relation to the processing of personal data for the purposes of the Regulation.
2. Training: specific, ongoing, documented
The measures must include participation in specific, ongoing training programmes designed to help people recognise operations which may be related to money laundering or terrorist financing and to instruct them how to proceed in such cases. Those programmes must be:
| Requirement | What it rules out |
|---|---|
| Specific | One generic module for the whole firm |
| Ongoing | Induction-only training |
| Appropriate to functions or activities | Identical content for an onboarding analyst and a treasury operator |
| Appropriate to the risks the entity is exposed to | Off-the-shelf content with no link to the firm’s own risk assessment |
| Duly documented | Delivery without a retained record of who, what and when |
The two-part aim is worth designing against explicitly. “Recognise” is a detection outcome; “how to proceed” is a procedural one. Training that covers typologies without covering the internal escalation route produces people who spot things and do not know what to do next — which is the failure mode that shows up in a file review as an unescalated observation.
3. Agents and distributors
Extending the duty to agents and distributors has three practical consequences for a network operator:
- Delivery. You need a mechanism to train people who are not your employees, and evidence of their participation — which usually means contractual obligations plus a platform, rather than goodwill.
- Consistency with what you told the supervisor. An agent notification under Article 19 of PSD2 must include a description of the internal control mechanisms the agent will use to comply with AML obligations. The training programme is part of what makes that description true, and the notification must be updated without delay on material change.
- Tipping-off. Article 73 binds agents and distributors to the prohibition on disclosure by name. Network-facing scripts and escalation guidance are therefore compliance artefacts, and getting them wrong exposes the network to a prohibition it may not know applies to it.
4. The neighbouring duties
Article 12 sits between two provisions that are usually implemented alongside it. Article 13 requires the integrity of employees, and Article 14 addresses reporting of breaches and protection of reporting persons, engaging Directive (EU) 2019/1937. A training programme that covers the internal whistleblowing route as well as the escalation route addresses both in one pass, and it is the cheapest place to do it.
FAQ
Do agents have to be trained?
Yes. Article 12 names agents and distributors expressly, both in the awareness duty and in the requirement to participate in specific, ongoing training programmes.
Is annual training enough?
The Regulation requires training to be ongoing and appropriate to functions and to the risks the entity faces. A fixed annual module with identical content for everyone meets the cadence and not the tailoring.
What has to be documented?
The training programmes must be duly documented. In practice that means retaining who was trained, on what content, when — and being able to show the content was appropriate to their function.
Related: Agents vs distributors · Tipping-off · The business-wide risk assessment
