What training will the EU Anti-Money Laundering Regulation require?

The Anti-Money Laundering Regulation, Regulation (EU) 2024/1624, is the EU's single rulebook for anti-money laundering and countering the financing of terrorism (AML/CFT). It was published in the Official Journal on June 19, 2024 and, under Article 90, applies from July 10, 2027, except for professional football clubs and football agents, for which it applies from July 10, 2029.

It is one part of a 2024 legislative package. The package also includes Directive (EU) 2024/1640, often called the sixth AML directive (AMLD6), which covers supervisors, financial intelligence units, and sanctions, and Regulation (EU) 2024/1620, which established the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) in Frankfurt am Main. As at September 2026 the AMLR is in force but not yet applicable, so current national laws built on Directive (EU) 2015/849 still govern training until July 10, 2027.

Article 12 requires obliged entities to make sure relevant people are aware of AML/CFT requirements and take part in specific, ongoing training. The first paragraph covers awareness: employees or persons in comparable positions whose function so requires, including agents and distributors, must be aware of the requirements of the AMLR, Regulation (EU) 2023/1113 on transfers of funds and crypto-assets, supervisory acts, and the entity's own business-wide risk assessment, internal policies, procedures, and controls, including on processing personal data.

The second paragraph sets the training standard. In the words of Article 12 of Regulation (EU) 2024/1624, the measures "shall include the participation of employees or persons in comparable positions, including agents and distributors, in specific, ongoing training programmes to help them recognise operations which may be related to money laundering or terrorist financing and to instruct them as to how to proceed in such cases." The training must be appropriate to people's functions or activities and to the risks the entity faces, and it "shall be duly documented."

Recital 40 of the Regulation adds that, where necessary, obliged entities should provide basic AML/CFT training to everyone with a role in implementing AML/CFT measures, including agents and distributors, not only employees.

Three further articles shape how training is governed and evidenced. Together they turn training from a stand-alone course into part of the internal control system.

• Article 9(2)(a)(x), training policy: internal policies must include "a policy on the training of employees and, where relevant, agents and distributors" covering the measures in place to comply with the AMLR, Regulation (EU) 2023/1113, and supervisory acts. Internal policies must be written and approved by the management body in its management function.
• Article 11, compliance functions: a member of the management body is appointed as compliance manager, responsible for ensuring policies are implemented and adequately resourced, and a compliance officer runs day-to-day AML/CFT policies, procedures, and controls. The compliance manager reports to the management body at least once a year on implementation, which in practice includes the training program.
• Article 13, integrity of employees: anyone directly participating in the entity's AML/CFT compliance, including agents and distributors, must undergo an assessment, with content approved by the compliance officer, of individual skills, knowledge, and expertise and of good repute, honesty, and integrity. The assessment happens before the person takes up the activity and is regularly repeated, with intensity set by the tasks and risks of the role.
• Article 16, groups: parent undertakings must apply the internal procedures, risk assessment, and staff requirements across branches and subsidiaries, including ensuring employees within the group are aware of AMLR requirements.

Article 13 matters for training design because it asks for evidence of knowledge and skills, not just attendance. A completion record shows that someone sat a course; a skills and knowledge assessment shows they can do the job. The difference is covered in completion tracking vs competency verification.

The core training duty is familiar, but the AMLR makes it uniform and adds explicit governance and assessment requirements. Under Directive (EU) 2015/849, training was set at directive level and detailed differently in each national law; the AMLR's correlation table maps that directive's Article 46(1) to Articles 12 and 15 of the Regulation.

Member States can keep some national rules where the Regulation permits, and Article 8(3) requires obliged entities to follow the national rules of the Member State where they are established in those areas. Groups should therefore plan one EU baseline curriculum plus national supplements.

Training sits in Chapter II of the AMLR, and Article 55 of Directive (EU) 2024/1640 requires Member States to impose pecuniary sanctions for serious, repeated, or systematic breaches of Chapter II, whether intentional or negligent. Maximum sanctions must be at least twice the benefit derived from the breach, where it can be determined, or at least EUR 1,000,000, whichever is higher.

For credit and financial institutions, Member States must also allow maximum sanctions on legal persons of at least EUR 10,000,000 or 10% of total annual turnover, whichever is higher, and at least EUR 5,000,000 for natural persons. National supervisors apply these once Member States have transposed AMLD6, which is due by July 10, 2027.

AMLA writes the detailed standards and guidelines that sit under the AMLR and will directly supervise a small number of high-risk cross-border financial entities. According to AMLA, it was legally established on June 26, 2024, and its timeline shows 40 obliged entities selected for direct supervision during 2027, with direct supervision starting during 2028.

Article 9(4) of the AMLR required AMLA to issue guidelines by July 10, 2026 on how size, nature, risk, and complexity affect the extent of internal policies, procedures, and controls, in particular staff allocated to compliance functions. As at September 2026, AMLA's public consultations page lists consultations on topics including business-wide risk assessment, customer due diligence, ongoing monitoring, and group-wide requirements, but none dedicated to training. Training teams should monitor final AMLA products, because business-wide risk assessment and ongoing monitoring guidance will change training content.

Start by mapping each AMLR training obligation to a learning outcome and the evidence that proves it, then compare the map to the current program. The table below is an illustrative mapping, not an official template.

1. Identify every role whose function requires AML/CFT awareness, including agents and distributors, and record it in a training matrix.
2. Link training content to the business-wide risk assessment so updates to risk trigger updates to content, following how to update training when regulations change.
3. Design Article 13 assessments that test knowledge and skills against defined competencies, as in how to design competency assessments.
4. Draft or revise the training policy for management body approval under Article 9.
5. Build records that show content version, date, role, and result, ready for an audit.

Knowledge Foundry models AMLR obligations, risk typologies, and role competencies as structured concepts with assessment points, then links each to the article it satisfies. When AMLA guidance or a national rule changes, the affected concepts and assessments can be identified and updated, and the evidence trail shows which version each person was assessed on.