Back to Resources
Training & Culture
Feb 02, 20267 min read

Why Annual AML Training is No Longer Enough: The New Continuous Learning Standard

The Central Bank and MoE now expect 'role-based' and 'continuous' education. Here is what your 2025 training calendar must look like.

Why Annual AML Training is No Longer Enough: The New Continuous Learning Standard

Gone are the days when a generic 1-hour PowerPoint presentation once a year satisfied the regulator. In 2025, the Central Bank of the UAE (CBUAE) and the Ministry of Economy have made it clear: training must be role-specific, continuous, and assessed.

The "Role-Based" Requirement

You cannot train your Receptionist and your Compliance Officer with the same material. Examiners now request to see the Training Needs Analysis (TNA) for each department.

  • Frontline Staff: Focus on "Red Flags" (e.g., nervous behavior, structuring cash).
  • Senior Management: Focus on "Liability," "Governance," and "Decision Making" for high-risk clients.
  • HR & Finance: Focus on "Employee Screening" and "Payroll Monitoring."

Frequency: The 30-Day Rule

New hires MUST be trained within 30 days of joining. If an employee handles a customer before being trained, it is a direct violation. Furthermore, "refresher" training must be triggered by events (e.g., a new Circular release), not just the calendar year.

Audit Tip:

Keep a "Training Register" that logs not just the date, but the test score of every employee. A training session without an assessment (quiz) holds little weight during an inspection.

Author: Zeej Strategic Consulting Research Team

Need help navigating these regulations?

Our experts are ready to assist you with GoAML registration, Risk Assessments, and Audit preparation.