AML training and employee training

1) Purpose and area

Build a "live" AML/CFT training program that ensures that each employee understands their role in preventing money laundering and terrorist financing, knows the signs and typologies, knows how to correctly escalate and formalize suspicions, complies with the tipping-off ban and works within the privacy/retention policy.

Coverage: all divisions (operations, support, payments, risk/AML, marketing and affiliates, data/analytics, legal, provider management, finance, information security/DPO), as well as contractors and temporary personnel.

2) Roles and RACI

AML Officer/MLRO - program owner, approves curriculum, cases, exams, reporting. (A)

Training Lead (L&D) - LMS, schedule, methodology, attendance control. (R)

Process Owners (Payments/CS/Risk/Data/Affiliates/Marketing/Legal) - adaptation of modules for processes. (R)

Compliance/Legal - compliance and localization. (C)

Internal Audit - independent audit of the program and verification of records. (C)

HR - inclusion in onboarding, disciplinary measures in case of failure. (R)

Exec Sponsor (COO/CRO) - resources, escalation by delay. (I/A)

3) Competence matrix (by role)

4) Curriculum (modules)

1. Introduction to AML/CFT and the role of iGaming: goals, risks, director and employee responsibility.
2. KYC/CDD/EDD: validation levels, sources, EDD triggers, KYC update, UBO/KYB for partners.
3. Sanction/POP screening: lists, matches, false positives, frequency of revisions.
4. Transaction monitoring: velocity, structuring, muling, bonus abuse, unusual deposit/withdrawal patterns, crypto/alt-pay.
5. SAR/STR: grounds of suspicion, content of the report, timing, channels, storage of confirmations.
6. No tipping-off: what cannot be said to the client; secure language in CS/marketing.
7. Affiliates and partners: KYB, red flags traffic, contractual arrangements.
8. Crypto risks/new methods: on-ramp/off-ramp, blending, blockchain footprint analytics (within policy).
9. Privacy/PII/GDPR: legality of processing, retention, minimization, access control.
10. Reporting and artifacts: investigation log, evidence base, decision logic.
11. Ethics and whistleblowing: how and where to report, employee protection.
12. Regional features: STR deadlines, bans, local triggers (market cards).

5) Training formats

Onboarding (0-14 days): basic course + test (minimum 85%).
Annual recertification: update of norms and typologies, new test (≥ 85%).
Role simulators: CS/Payments/AML scripts (chat scripts, phone, e-mail).

Table-top exercises (quarterly): end-to-end cases "hidden structuring/mule," "affiliate arbitration," "sanctions hit."

Micro modules (monthly): 10-15 min updates on typologies/regional changes.
Shadowing/Monitoring: internship with AML analysts for 1/2 lines.
Vendor workshops: KYC/AML/PSP providers talk about updates.

6) Knowledge assessment and certification

Formats: test (20-30 questions), case analysis (free-form), practical "check out transactions."

Threshold: 85% test + successful case analysis. Admission to the operational role - only if there is an up-to-date certificate.
Retest: after 7 days; in case of repeated failure - a coach session with the manager.
Certificate: number, date, course/version, validity period, electronic signature. Storage in LMS with export to HRIS.

7) LMS and Accounting

Catalog of courses with versions, locales, mandatory.
Role/location assignments, deadlines, and reminders.
Protocols: passing, tests, certificates, attempts, retests.
Integration: SSO, HRIS (onboarding/dismissal), AML dashboards (coverage, delinquencies).
Retention: Training logs are kept as per policy (usually 5-7 years).

8) Performance Metrics (KPI/KRI)

Coverage:% of employees with a current certificate (target ≥ 98%).
On-time Completion:% completed before deadline (target ≥ 95%).
Pass Rate/Average Score: Percentage passed/average score.
Time-to-SAR: median from signal to SAR delivery (should improve after training).
False Positive Rate (investigations): filtration stability/quality.
Escalation Quality: Share of cases with a full evidence base.
Post-Training Impact: reduction of tipping-off incidents, correctness of CS communications.
Training NPS: assessing the usefulness of modules.

9) Checklists

9. 1 Before starting the course

• The current version of the AML/Sanctions/EDD policy is loaded into the LMS.
• Local market requirements and STR deadlines are included.
• Updated scenarios and cases in the last 6-12 months.
• Assigned role courses, deadlines, and reminders.
• Integration with HRIS (onboarding/offboarding) is set up.
• Pilot group (10-20 persons) , feedback is taken into account.

9. 2 During the course

• LMS Technical Support/Access.
• Answers to questions (forum/chat).
• Capture retries and transit times.

9. 3 Closing and control

• Exports certificates and logs to the audit store.
• Dashboard: coverage, delinquencies, pass rate.
• MLRO Report to Management/Audit Committee.
• Content and practice improvement plan.

10) Scripts (role-play) - quick inserts

A) CS: inhibit tipping-off

The customer asks, "Why is my withdrawal delayed?"

The correct answer is "We do a standard security payment review. Once the review is complete, you will be notified. Thank you for your understanding. "(no hint of suspicion/AML).

B) Payments: structuring/velocity

A series of deposits of 990 units in 30 minutes, different cards, one IP.
Actions: escalation in AML, freezing of conclusions until completion of verification, collection of documents by means.

C) AML: Sanctions hit

Match per POP/average confidence sanctions.
Actions: re-verification, alternative sources, decision on restrictions, entry into the case with justification.

D) Affiliates: Dirty Traffic

Unusually high "high risk" GEO ROI, repetitive devices.
Action: KYB review, payment suspension, partner notification, report to Risk.

E) Crypto on-ramp

Withdrawals to the wallet associated with the mixer.
Action: chain analytics, EDD, possible SAR, policy/law hold.

11) Templates

Certificate of completion: full name, course/version, date, expiration date, MLRO signature, QR/ID.
Exam (example): 25 questions (multiple selection), 2 cases open-ended.
CS scripts (bank secrecy, correct answers).
AML escalation form: who/when/what saw, customer/transaction ID, artifacts.
Lesson plan (90 min): 15" input → 25" module → 20" case → 20" test/poll → 10" feedback.

12) Localization and availability

Courses in the languages of the markets; examples and cases - local (banks/methods/regulators).
Subtitles and accessible format for employees with special needs.
Time zones and shift schedules are repeat slots.

13) Content Change Management

Versioning: vMAJOR. MINOR. PATCH; change log.
Audit triggers: new laws/sanctions, incidents, test failures, audit/regulator findings.
Process: draft → Jurassic review → pilot → release → communication.

14) Training program audit

Internal Audit: annual audit: completeness, timeliness, quality of assessment, correctness of records, selection of certificates.
External inspections: provision of journals, programs, cases, evidence of passage; mapping to roles.
CAPA: correcting gaps (for example, delays in individual teams), training mentors.

15) Implementation plan (30 days)

Week 1

1. Assign MLRO owner and L&D coordinator.
2. Approve the matrix of roles and mandatory modules.
3. Collect original content: AML/sanctions/EDD policy, regional requirements.

Week 2

4. Deploy LMS, import employees, set up SSOs and roles.
5. Prepare a basic course (modules 1-7) and a test, localization of key languages.
6. Configure Coverage/On-time/Pass Rate dashboards.

Week 3

7. Pilot on 2-3 teams (CS, Payments, Risk).

8. Table-top exercise "structuring + sanctions hit."

9. Collect feedback, correct cases and tests.

Week 4

10. Mass launch (all roles), deadlines 14/21 days by priority.
11. MLRO report on guidance, retest plan and micro-modules for 90 days.
12. Start KPI monitoring and prepare for program audit.

• Incident Playbooks and Scripts (FIU/SAR/STR)
• Notices of Violations and Reporting Deadlines
• Compliance dashboard and monitoring
• Regulatory reports and data formats
• Internal Audit and External Audit
• Audit checklists and reviews
• License renewals and inspections
• Regulatory changes by region