AML training records: what your supervisor expects

In short

• Relevant employees must be made aware of the law and regularly trained, and you must keep a written record of it (regulation 24).
• The record shows what training was given, when, who received it and the results of any assessment (AMLGAS 7.4.2; ACCA's FAQs).
• ACCA's return asks about training for staff and, separately, the MLRO's own formal training in the past two years. Reading policies and on-the-job training do not count (pages 16 and 17).
• Training does not have to come from an outside provider. It does have to cover the right topics and be kept on file.

1

Who

Each relevant employee, and the MLRO

2

What

The topics, and a copy of the materials

3

When

The date of each session

4

Result

The outcome of any test or check of understanding

1. What the law asks

The duty is regulation 24 of the Money Laundering Regulations 2017. It has two parts. First, the right people must know the law and be trained.

made aware of the law relating to

The full sub-paragraph covers the law on money laundering, terrorist financing and proliferation financing, and the data protection requirements relevant to the regulations. The next one asks for regular, practical training: staff are “regularly given training in how to recognise and deal with transactions and other activities or situations which may be related to” those risks. Second, you must be able to show it.

maintain a record in writing of the measures taken under sub-paragraph (a), and in particular, of the training given to its relevant employees

A relevant employee is someone whose work matters to your AML compliance or who could help spot or prevent money laundering (regulation 24(2)). ACCA's FAQs (2025 edition) give an example of who is not: “we would not consider a secretary, personal assistant or facilities staff to be considered a relevant employee”.

If HMRC supervises you, its manual for officers visiting accountancy practices says the same.

In all cases, the training provided to staff of an ASP must be recorded.

2. What the training should cover

HMRC's manual points accountancy practices to the CCAB guidance, saying it is “published by CCAB on behalf of the accountancy professional bodies and agreed with HMRC and HM Treasury”. That guidance, AMLGAS, lists what a training programme should include.

The programme itself should include:

• An explanation of the law within the context of the business’s own commercial activities;
• The requirement to carry out CDD and conduct ongoing monitoring, including how to carry out CDD, the purpose of CDD and how to use the information gathered in providing defined services;
• When it is appropriate to make an internal report to the business’s MLRO and how to do so;

The same list goes on to red flags, how to deal with situations that might be suspicious, confidentiality and how to avoid tipping off, and the data protection requirements (8.3.2). AMLGAS 8.3.3 asks for training tailored to the services you provide and the clients you deal with. ACCA's FAQs set a minimum.

At a minimum, it is expected that training covers the following areas:

• AML red flags (e.g., how to identify suspicious activity)
• Explaining the law and regulations and placing them in the context of the firm’s business activities
• Conducting customer due diligence (CDD)
• SARs and how to deal with suspicious transactions
• Tipping off
• Record keeping

3. What does not count

ACCA is direct about this, in its FAQs and on the return itself.

‘On the job training’ (e.g., providing feedback and reviewing work), reading policies and procedures and regular meetings are not considered AML training.

Have you provided AML training to all relevant employees? (Please note: we do not consider employees reviewing the firm's AML policies and procedures or receiving 'on-the-job' training to be sufficient AML training.)

The MLRO's own training has its own question, with its own note.

As the MLRO, have you completed formal AML training within the past two years? (Please note, we do not consider reading articles or publications to be formal AML training.)

Training can still take many forms. AMLGAS 8.3.1 says it “can be delivered in several different ways: face-to-face, self-study, e-learning, video presentations, or a combination of all of them”. ACCA's FAQs say “MLROs can produce their own training materials, so long as they cover off the above-mentioned topics with the appropriate detail.”

4. What the record shows

This is the part a supervisor can check. AMLGAS 7.4.2 says the records:

should show the training that was given, the dates on which it was given, which individuals received the training and the results from any assessments.

ACCA's FAQs use almost the same words, and add the materials.

Firms must also maintain training records that show the training that was given, the dates on which it was given, which individuals received the training and the results from any assessments.

Copies of training materials, including presentation slides, booklets, leaflets and any other accompanying material should be retained.

A test is worth considering. AMLGAS 8.3.5 says “A system of tests, or some other way of confirming the effectiveness of the training, should be considered.” ACCA's FAQs advise a post-course assessment for the same reason.

Column	What to write	Source
Who	The name and role of each person trained	AMLGAS 7.4.2; ACCA FAQs, page 7
What	The training given, its topics, and where the materials are kept	AMLGAS 7.4.2, 8.3.2; ACCA FAQs, pages 6 and 7
When	The date it was given	AMLGAS 7.4.2; ACCA FAQs, page 7
Result	The outcome of any test or other check of understanding	AMLGAS 7.4.2, 8.3.5; ACCA FAQs, page 7
MLRO	The date of the MLRO's last formal AML training	ACCA 2026/27 return, page 17

5. When to train

Regulation 24 says training is given regularly. AMLGAS adds two points.

Businesses need to make sure that new relevant employees and agents are trained promptly.

The frequency of training events can be influenced by changes in legislation, regulation, professional guidance, case law and judicial findings (both domestic and international), the business’s risk profile, procedures, and service lines.

ACCA's return offers five answers for staff training, from "Yes - conducted periodically or regularly" through "Yes - to new staff only" to "No" (page 16), and asks about the MLRO's formal training within the past two years (page 17).

6. Why it matters, and who looks

AMLGAS is plain about the risk of not training.

A business that fails to provide training for relevant employees (and agents where appropriate) could be in breach of the regulations and at risk of prosecution.

It also says someone should own it.

A designated person should be made responsible for the detail of AML training. This could be the MLRO or a member of senior management.

Supervisors ask to see the record. ACCA's own checklist asks “Have records been kept of the training given to relevant employees?” and answers “Records must be kept that show who has received training, the training received and when training took place.” HMRC's manual tells its officers that where a practice has employees, it “should be assessed for compliance with the training obligations under Regulation 24”. And among his checks before the 2026/27 ACCA return, David Winch lists “Whether AML training records are available for the MLRO and staff”.

How PracticeGuard helps

The AML return pack includes a training register, written from your interview answers, with a section for the MLRO's own formal training and one for what the training should cover. The ACCA sheet answers the return's training questions from the dates you record. The pack does not deliver AML training itself. PracticeGuard Shield, coming soon, adds AML training for your team and more, priced at launch.

Questions people ask

Sources

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017Revised text as at 30 June 2026 · legislation.gov.uk
• CCAB, Anti-Money Laundering, Counter-Terrorist and Counter Proliferation Financing Guidance for the Accountancy Sector (AMLGAS)July 2026 · CCAB
• ACCA, AML Annual Return FAQs2025 edition · ACCA
• ACCA, 2026/27 Anti-Money Laundering (AML) Annual Return - UKThe published form, 20 pages · ACCA
• ACCA technical factsheet, Anti-money laundering (AML): Am I AML compliant?Issued January 2024
• HMRC, Economic Crime Supervision Handbook, ECSH52800: compliance intervention at an accountancy service providerUpdated 27 August 2026 · GOV.UK
• HMRC, Anti-money laundering guidance for supervised businesses, AMLG2000: Accountancy Service Provider GuidanceUpdated 13 October 2026 · GOV.UK
• David Winch (MLRO Support), "The latest ACCA AML return: A sting in the tail?"AccountingWEB, 14 October 2026 · AccountingWEB

PracticeGuard supports your judgement; it never replaces it. This page describes what the Money Laundering Regulations 2017, the accountancy sector guidance and the supervisors’ own published documents say, with the source for each point, so you can read it yourself. It is not legal advice, and nothing here is advice about what your supervisor will accept. PracticeGuard is not affiliated with or endorsed by ACCA, ICAEW, AAT, HMRC or any AML supervisor. Check the current version of each document before you rely on it.