How to Train Your Staff for AML Compliance in the UAE Without Breaking the Bank

Introduction

You don’t need to spend thousands on fancy AML seminars to stay compliant. But you do need to prove that your team understands their Anti-Money Laundering (AML) obligations, and that starts with proper training.

For Designated Non-Financial Businesses and Professions (DNFBPs) in the UAE, including real estate, gold trading, law firms, and company service providers, AML inspections now regularly include questions about staff awareness. Inspectors want to see more than a policy document. They want training evidence.

So how do you deliver meaningful AML training without burning your budget?

Let’s break it down.

Why AML Training Is Non-Negotiable

Failure to train staff is a violation under Cabinet Resolution No. (10) of 2019 and is listed among the 41 administrative fines under Cabinet Decision No. (71) of 2024.

Training is especially important because:

• Your staff are the first line of defense, they must spot red flags.
• Ignorance is not an excuse in regulatory inspections.
• Inspectors will ask for proof, not promises.

What Inspectors Usually Ask

During inspections, AML officers and Ministry of Economy teams typically ask:

• Who received AML training?
• When was the training delivered?
• What topics were covered?
• Is there a training log?
• Were the MLRO and senior management trained?
• Do you have training certificates?

They may also ask for sample materials or evidence that the training matched your business risks.

What Counts as Acceptable Training Evidence

You don’t always need to send staff to expensive third-party courses. The following are usually accepted:

• Training Log – A dated record of who was trained, when, and on what topics
• Certificate of Attendance – Issued internally or externally, even without an exam
• Training Materials – Slides, PDFs, or videos used during the session
• Trainer Info – Name and role of the person conducting the session
• Policy Reference – Mention of training procedures in your AML/CFT policy

Note: While external training is useful, internal training is fully acceptable, provided it’s documented and aligned with your risk profile.

Who Can Deliver the Training?

• Internal MLRO or Compliance Officer – Most common and cost-effective
• External AML Consultants – Ideal for high-risk sectors or first-time training

Unqualified staff – Avoid ad-hoc, undocumented sessions by non-experts

There’s no rule requiring the trainer to be "certified," but they must be competent and the session must be clearly recorded.

What AML Topics Should Be Covered?

While the UAE regulations don’t prescribe an exact syllabus, they expect training to cover these essential areas:

• Basics of AML/CFT laws in the UAE
• Customer Due Diligence (CDD/EDD) requirements
• Red flags for suspicious transactions
• Politically Exposed Persons (PEPs) handling
• Record-keeping and audit trails
• goAML reporting and escalation process
• Role of staff and management in compliance

Optional (but useful) additions:

• Use of AML software (if applicable)
• Sector-specific risks (e.g., real estate payments, gold cash deals)

How Often Should You Train?

• At onboarding – For all new hires
• Annually – Minimum for all relevant staff
• When there are changes – In law, regulation, or internal procedures

Some firms schedule refresher sessions every 6 months, especially those with higher volumes of risky clients or transactions.

Low-Cost and Effective Training Ideas

• Use free online AML videos (FATF, MOE, YouTube from reliable sources)
• Run internal training using your own MLRO or compliance staff
• Create a simple training checklist and printouts for attendance signing
• Use InfoAML’s built-in training docs to save time
• Customize training around your recent compliance issues or inspection findings

Final Reminder: Training Without Proof = No Training

It’s not enough to say your team is trained. You must:

• Keep evidence
• Stay consistent
• Update content when needed

AML training is one of the most cost-effective ways to reduce inspection risk, and demonstrate your firm’s commitment to compliance.

Bonus: How InfoAML Helps You Stay on Top of AML Training Records

AML inspections often include questions like:

“Can you show us proof that your staff have been trained recently?”

“Do you have a training attendance log or certificates on file?”

With InfoAML, you're not left scrambling.

Here’s how we help you stay inspection-ready:

• Training Documentation Upload
  Store all your AML training records, including attendance sheets, internal memos, and certificates, directly in InfoAML’s secure Document Management module.
• Staff-Level Organization
  Link training files to specific employee profiles. Whether it’s the compliance officer, sales agent, or admin staff, you’ll have documented proof of who received what training and when.
• Accessible Evidence During Inspections
  When regulators ask, you won’t be hunting through folders or email attachments. Training records are organized and easy to retrieve, even during a live inspection.
• Ready for Customization
  Need more in the future? InfoAML can be extended to support custom logs, automated reminders, or training dashboards, depending on your company’s compliance needs.

InfoAML helps DNFBPs across the UAE stay compliant, not just in theory, but with provable, organized evidence of AML training and much more.

👉 Book a Free Demo

See how InfoAML keeps your training records inspection-ready, and your business one step ahead of regulators.