Art. 12 Awareness of requirements | Anti-money laundering regulation (AMLR) | AML

This article deals with staff awareness and training obligations for obliged entities.

It builds directly on the internal policies, procedures and controls framework established in Article 9, requiring that those policies are not just documented but actively communicated to and understood by the people responsible for implementing them.

The article covers both awareness of the regulatory requirements and the practical knowledge needed to identify and respond to suspicious activity.

Important points:

Ensure all relevant employees, agents and distributors are aware of AML/CFT requirements, the business-wide risk assessment, and internal policies — including on personal data processing.
Deliver specific, ongoing training programmes to help staff recognise and respond to potential money laundering or terrorist financing activity.
Training must be tailored to the functions and risk exposure of the individuals concerned, and must be duly documented.

Obliged entities shall take measures to ensure that their employees or persons in comparable positions whose function so requires, including their agents and distributors are aware of the requirements arising from this Regulation, Regulation (EU) 2023/1113 and any administrative act issued by any supervisor, and of the business-wide risk assessment, internal policies, procedures and controls in place in the obliged entity, including in relation to the processing of personal data for the purposes of this Regulation.
The measures referred to in the first paragraph 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. Such training programmes shall be appropriate to their functions or activities and to the risks of money laundering and terrorist financing to which the obliged entity is exposed, and shall be duly documented.