AML Training Requirements for Accountants and Accounting Firms in 2026

AML Training Requirements for Accountants and Accounting Firms in 2026

Anti-money laundering (AML) training is a legal requirement for accountants and accounting firms across the UK and Ireland. Failure to maintain adequate AML training programmes exposes firms to regulatory sanctions, unlimited fines, and — in serious cases — criminal prosecution. In 2026, regulators are intensifying scrutiny, making it more important than ever that firms understand exactly what is required, how often training must occur, and how to demonstrate compliance.

This article sets out the full legal basis for AML training obligations, what training must cover, how frequently it must be completed, what records to keep, and how to demonstrate compliance to supervisory bodies.

---

The Legal Basis for AML Training in the UK and Ireland

United Kingdom

In the United Kingdom, AML training obligations for accountants derive from multiple legislative and regulatory sources:

• Proceeds of Crime Act 2002 (POCA 2002): The primary UK legislation on money laundering. Part 7 of POCA criminalises money laundering and creates the obligation for "nominated officers" (Money Laundering Reporting Officers) to receive and assess internal suspicious activity reports (SARs). Firms whose staff are inadequately trained cannot discharge these obligations.
• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017): Regulation 24 requires that relevant employees are made aware of the law relating to money laundering and terrorist financing, and that they receive training in how to recognise and deal with transactions or situations which may be related to money laundering or terrorist financing.
• Fifth Anti-Money Laundering Directive (5AMLD): Incorporated into UK law via the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, 5AMLD extended AML requirements to additional categories of accountancy services and tightened due diligence obligations.
• Terrorism Act 2000: Creates additional obligations relating to terrorist financing awareness.

Ireland

In Ireland, the legal basis for AML training is primarily:

• Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010), as amended by the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021, which transposed the Fifth AML Directive into Irish law. Section 54 of the CJA 2010 requires designated persons (which include accountants and auditors) to take measures to make relevant employees aware of the law relating to money laundering and terrorist financing and to provide them with regular training.
• Central Bank of Ireland (CBI) guidance adds further expectations around training frequency, content, and record-keeping.

---

Who Is Subject to AML Training Requirements?

In both jurisdictions, AML training requirements apply to "relevant employees" — generally any member of staff who is involved in activities covered by AML legislation. For accounting firms, this includes:

• Partners and principals
• Qualified accountants in client-facing roles
• Bookkeepers and accounts staff handling client transactions
• Tax advisers and payroll staff
• Any member of staff who may receive or act on instructions from clients

Back-office staff with no client contact are generally not subject to full AML training requirements, though basic awareness training is considered good practice.

---

What AML Training Must Cover

Regulatory guidance from HMRC, ICAEW, ACCA, and the CBI) is consistent on the content that AML training programmes must address;

• The legal framework: POCA 2002 (UK) or CJA 2010 (Ireland), the relevant AML Regulations, and the Terrorism Act
• What constitutes money laundering and terrorist financing: definitions, typologies, and real-world examples
• Customer due diligence (CDD): what CDD is required, when enhanced due diligence applies
• Recognising red flags and suspicious activity: transaction patterns, client behaviour
• The suspicious activity report (SAR) process: how to make an internal SAR, the role of the MLRO
• Sanctions screening: awareness of HM Treasury's consolidated sanctions list
• Firm-specific policies and procedures: staff must be trained on their firm's specific AML policies

---

How Often Must AML Training Be Completed?

Regulation 24 of MLR 2017 and Section 54 of CJA 2010 both require "regular" AML training. The industry standard is:

• Annual training for all relevant staff as the baseline
• More frequent updates when there is a significant change in legislation or identified risk
• Training at onboarding for all new relevant employees

---

What Records Must Firms Keep?

Both UK and Irish AML regulations require firms to maintain adequate records of training activity. Records+should include:

• The name of the employee trained
• The date training was completed
• The content or course title covered
• Evidence of completion (certificate, assessment result, attendance record)
• The name of the training provider

Records should be retained for a minimum of five years.

---

How to Demonstrate Compliance to Regulators

When a supervisory body conducts a review, they will typically request:

• The firm's AML policy and procedures document
• Training records for all relevant staff demonstrating annual completion
• Evidence that the MLRO has received appropriate training
• A log of internal SARs submitted in the review period
• Evidence of ongoing client risk assessments and CDD procedures

---

Online vs In-Person AML Training

Both online and in-person AML training are fully valid for regulatory purposes. Online AML training offers significant practical advantages:

• Staff can complete training at a time that suits them
• Platforms automatically issue certificates and maintain completion records
• Content can be updated quickly when legislation changes
• Cost per user is typically lower than classroom training

---

Frequently Asked Questions

Is AML training a legal requirement for accountants?

Yes. In the UK, Regulation 24 of the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 requires accounting firms to provide regular AML training to relevant employees. In Ireland, Section 54 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 imposes the same obligation.

Does online AML training count as verifiable CPD?

Yes. Online AML training completed through a recognised provider, with a certificate of completion or assessment result, counts as verifiable CPD under ACCA, ICAEW, CIMA, and CPA Ireland frameworks.

Who is responsible for AML training in an accounting firm?

The Money Laundering Reporting Officer (MLRO) has primary operational responsibility for AML training. However, regulatory accountability rests with the firm's principals or partners.

---

Access Learnsignal's AML training course — fully compliant with UK and Irish regulatory requirements. Visit learnsignal.com/resources/ to get started.