For company directors
Is your company subject to anti-money laundering legislation, but does your staff still apply the rules inconsistently today? Anti-money laundering training is not a one-off session: the law requires a permanent programme that grows with your company’s risks.
What does the law actually require in terms of training?
Article 11 of the Law of 18 September 2017 requires measures that let your relevant staff know and understand the law, the implementing decrees, the data protection rules and your own internal procedures. That means explicit participation in special permanent training programmes, not a single introduction on hiring.
The people you appoint to analyse atypical transactions and make reports to the financial intelligence unit must first demonstrate reliability, expertise and availability, with sufficient hierarchical authority. Training that underpins that level of expertise is therefore not a needless extra, but part of the statutory condition for appointing them.
The law also works with a risk-based approach: you carry out the preventive measures in a differentiated way, based on your own assessment of the risk of money laundering and terrorist financing. Your training should therefore be proportionate to the clients, products and countries your company deals with, not a generic module identical for every sector.
One person may combine the role of report manager and that of training lead where the nature and size of your company justify it. If the legislation changes, we expect you to update your training accordingly: a programme that is never refreshed does not meet the requirement of a permanent programme.
The supervisor your company falls under also varies with your activity: the National Bank of Belgium for credit institutions, the FSMA for part of the insurance sector, and your own chamber or institute for accountants and estate agents. Tailored training takes account of the expectations of your own supervisor.
How does tailored training work with Everest (anti)fraud?
We develop tailored training based on your specific needs. You supply us with your questions and case studies, and we build a training course around them that enables your staff to comply with AML obligations as effectively as possible.
After every session, you receive a short report of the points raised during the training. That report helps you keep track of who attended which training, something a supervisor often asks about explicitly during an inspection.
Training works best after an aml audit that first maps the concrete gaps: that way you know in advance which topics your staff need most. We often bring the manager of your whistleblowing procedure into the same session, since both channels need to recognise similar signals.
You will find more background on the underlying duties on our page about anti-money laundering legislation, and good training also fits within a wider corporate fraud policy for your company. Back to our page for company directors.
Our training runs both as group sessions and in smaller working sessions, and we adapt the format to the number of participants and the available budget. A new employee in a key role preferably receives a short introduction session within their first months in post.
Frequently asked questions
Does anti-money laundering legislation require permanent training?
Yes, article 11 of the Law of 18 September 2017 requires special permanent training programmes for relevant staff, not a one-off session on hiring. The training must let your staff know and understand the law, the implementing decrees, the data protection rules and your own internal procedures.
Who within the company must demonstrate competence for AML purposes?
The person or people you appoint to analyse atypical transactions and make reports to the financial intelligence unit. They must first demonstrate reliability, expertise and availability, with sufficient hierarchical level and authority to carry out their task effectively.
Does the training adapt to my company’s level of risk?
Yes, the law requires a risk-based approach, so your training must be proportionate to your own risk of money laundering and terrorist financing. A company with many foreign clients needs different emphases from a company that works almost exclusively at national level. We discuss those emphases with you beforehand during a short intake conversation.
Do you receive a report after the training?
After every session, you receive a short report of the points raised during the training. That report helps you keep track of who attended which training, something a supervisor often asks about explicitly during an inspection.