AML Rollout Checklist
AML & KYC Training Template and Checklist
A ready-to-run AML and KYC program and the rollout checklist to go with it. Train every regulated role, then see who is actually covered.
✓ Reviewed by Abhijit Rao, AVP & Business Head, India
- A seven-module AML and KYC program, with audience and coverage for each
- A rollout checklist mapped to your AML policy and regulator expectations
- A team coverage matrix that shows where regulated teams are thin
- An annual refresher and new-joiner training cadence
What is inside
- A seven-module AML and KYC program, with audience and required coverage for each session.
- A 10-point rollout checklist you can map to your AML policy and regulator expectations and mark off as you go.
- A team coverage matrix that scores each regulated team and shows where training is thin.
- An annual refresher and new-joiner training cadence so completion stays current and evidenced.
Who it is for
Anyone who has to plan what people learn, and answer for whether it landed.
- L&D and training teams
- People managers and team leads
- Heads of function and department
- HR business partners
- Compliance and risk teams
- Onboarding and enablement teams
- Operations and delivery leads
- COOs and HR directors
How to use this template in 4 steps
- Pick your format. Download the PDF to share, the Word file to edit, or the Excel file to work in live. All three are free.
- Make it yours. Adapt the sections, fields and wording to your team, roles and process so it fits how you actually work.
- Put it to work. Fill it in, circulate it to stakeholders for sign-off, or roll it out to your team.
- Track and improve. Review it on a set cadence and refine it as your goals, roles and priorities change.
What is inside
- A seven-module AML and KYC program, with audience and required coverage for each session.
- A 10-point rollout checklist you can map to your AML policy and regulator expectations and mark off as you go.
- A team coverage matrix that scores each regulated team and shows where training is thin.
- An annual refresher and new-joiner training cadence so completion stays current and evidenced.
This is practitioner guidance, not legal advice. AML and KYC obligations are set by regulation and differ by jurisdiction and sector. Adapt the modules and checklist to your own policy and have your MLRO, legal or compliance team confirm your obligations.
The training program template
Seven modules covering customer due diligence through to reporting and sanctions. Run the core set for all regulated staff, then use the deep-dive and refresher for front office and monitoring roles through the year.
| Module | Audience | Duration | What it must cover |
|---|---|---|---|
| 1. AML fundamentals | All regulated staff | 20 min | What money laundering and terrorist financing are, the three stages, and your obligations and liability. |
| 2. Customer due diligence and KYC | Onboarding, front office | 35 min | Identity verification, beneficial ownership, risk rating the customer, and when enhanced due diligence applies. |
| 3. Politically exposed persons | Onboarding, front office | 20 min | Identifying PEPs and their associates, the enhanced measures required, and senior sign-off. |
| 4. Transaction monitoring | Monitoring, operations | 30 min | Recognising unusual patterns, structuring and layering, and handling alerts and thresholds. |
| 5. Suspicious activity reporting | All regulated staff | 25 min | Spotting red flags, escalating to the MLRO, the no-tipping-off rule, and the internal report path. |
| 6. Sanctions and screening | All regulated staff | 20 min | Sanctions lists, screening at onboarding and payment, matches and blocks, and escalation. |
| 7. Annual refresher | All regulated staff | 20 min | New typologies, regulatory and sanctions updates, and a short knowledge check for evidence. |
Delivering the refresher and knowledge check through an LMS gives you dated completion per person and per regulated role, the exact evidence a regulator or auditor asks for during an AML exam.
The rollout checklist
Ten steps to get AML and KYC training live and evidenced. Tick items to track your own progress, it stays in this browser. The download has the same list with an owner column.
- AML policy published and attestation recordedPolicyAnnual
- New joiners trained before customer or payment contactOnboardingPer hire
- CDD and KYC procedures trained for onboarding and front officeDue diligenceAnnual
- PEP identification and enhanced due diligence coveredDue diligenceAnnual
- Transaction monitoring trained for monitoring and operationsMonitoringAnnual
- Suspicious activity reporting path drilled to the MLROReportingAnnual
- Sanctions screening and escalation coveredSanctionsAnnual
- Dated completion tracked by role, not just company-wideGovernanceOngoing
- Annual refresher and knowledge check completedGovernanceAnnual
- Internal reports reviewed for quality and timelinessGovernanceQuarterly
The most common gap is new joiners. A frontline hire taking customers before CDD training is exactly the failure a regulator flags, and a company-wide completion number will not show it.
Team coverage at a glance
The checklist tells you what is missing overall. This matrix tells you which regulated teams are behind. Score each team on the five areas that carry the most AML risk. In Excel the coverage and gaps calculate as you type.
| Team | People | CDD / KYC | PEPs | Monitoring | SAR reporting | Sanctions | Ready |
|---|---|---|---|---|---|---|---|
| Financial crime | 30 | 2 | 2 | 2 | 2 | 2 | 100% |
| Onboarding | 55 | 2 | 1 | 1 | 2 | 1 | 70% |
| Relationship mgrs | 80 | 1 | 1 | 0 | 1 | 1 | 40% |
| Payments ops | 70 | 1 | 0 | 2 | 1 | 1 | 50% |
| Contact centre | 140 | 1 | 1 | 1 | 1 | 0 | 40% |
| Coverage at required | 40% | 20% | 40% | 40% | 20% | 60% |
Relationship managers are the exposure here: no transaction-monitoring training in the team closest to the customer relationship, and monitoring is where laundering typically shows up.
The annual AML calendar
| Timing | Action | Owner |
|---|---|---|
| Before customer contact | Fundamentals, CDD and reporting for every new regulated hire, recorded. | Compliance and L&D |
| On moving into a regulated role | Role-specific deep dive before the role starts. | Compliance |
| Annual, all regulated staff | Refresher and knowledge check, tracked by role. | MLRO and L&D |
| On typology or sanctions change | Targeted update for the affected teams, fast. | Compliance |
| Quarterly | Review completion by role and the quality of internal reports. | MLRO |
| After any weakness found | Remedial training for the team involved, documented. | Compliance |
How to run it
- Map training to regulated roles
Front office, onboarding, payments and monitoring each need different depth. Start from who does what, not a single company-wide course.
- Train new joiners before customer contact
Anyone handling customers or payments needs CDD and reporting training before they start, not in their first quarter.
- Drill suspicious activity reporting
The goal is that a frontline person recognises a red flag and knows exactly how to escalate to the MLRO without tipping off.
- Track dated completion by role
Roll it up per regulated team so a gap is visible to you before it is visible to a regulator.
- Refresh annually and on typology changes
New money-laundering typologies, sanctions changes and regulatory updates trigger a refresh, not just the calendar.
- Review coverage and reporting quarterly
Completion by role, quality of internal reports, and time from red flag to MLRO decision.
Frontline teams reach 45 percent-plus completion on Disprz when training is delivered in short, mobile modules in the local language, the format this program is built for.
Common mistakes this pack prevents
- One company-wide AML course, when a relationship manager and a payments analyst need very different depth.
- New joiners taking customers before they have completed CDD and reporting training.
- Teaching red flags but never drilling the actual escalation path to the MLRO.
- Treating sanctions screening as an IT control instead of training the people who act on a match.
- No dated completion records by role, so there is nothing to hand a regulator during an exam.
Which format should you use?
| Format | Best for | What is inside | Editable | Size |
|---|---|---|---|---|
| PDF PDF | Sharing and print | The full template, formatted to print or circulate | No | 55 KB |
| WORD Word | Editing the wording | Every section as editable text you can adapt | Yes | 86 KB |
| EXCEL Excel | Filling it in live | The grid and fields set up as a working spreadsheet | Yes | 66 KB |
Questions people ask
Is AML and KYC training mandatory?
How often should AML training happen?
What is the difference between AML and KYC?
Can I adapt the modules and checklist?
Do I have to fill the form three times?
AML training only counts if regulated teams finish it and you can prove it. That is the part we run.
Bring your teams to a 30-minute working session. We will show how Disprz delivers AML and KYC training in short mobile modules in the local language, and rolls dated completion up by role, so your next regulatory exam or audit is a two-minute export.
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