Knowledge

Does AML training have to take place every year?

The Anti-Money Laundering Act (AMLA) does not prescribe a fixed frequency. It requires adequate training of staff (Art. 8 AMLA); for financial intermediaries supervised by FINMA, the AMLO-FINMA specifies regular training (Art. 27 para. 2). SRO members must follow the frequency set out in their SRO’s regulations – at PolyReg this is annual further training, at VQF further training every two years.

Last updated: 25 October 2026 · Author: Iman Gonzalez Prada

What the law requires

Art. 8 AMLA requires all financial intermediaries to take the organisational measures needed to prevent money laundering and terrorist financing; in particular, they must ensure adequate training of their staff and carry out controls. Since 1 October 2026, the same obligation applies word for word to advisors (Art. 8d AMLA). The Act does not specify a frequency such as once a year.

FINMA-supervised institutions

For banks, asset managers, trustees and the other financial intermediaries supervised by FINMA, the AMLO-FINMA specifies the obligation in three places:

Art. 27 para. 2: the financial intermediary ensures regular training of all employees concerned on the aspects of combating money laundering and terrorist financing that are relevant to them.
Art. 26 para. 2 let. e: the internal directives must set out the principles of employee training.
Art. 24 para. 2: the anti-money laundering unit plans and monitors internal training.

What “regular” means in practice is therefore determined by the institution itself – in its internal directives and in line with its risks. The ordinance does not prescribe a fixed frequency such as once a year.

SRO members

Financial intermediaries under Art. 2 para. 3 AMLA and advisors must join a self-regulatory organisation (Art. 14 AMLA). How often training takes place is set out in the regulations of the respective SRO. Two examples:

PolyReg: training consists of basic training and annual further training (§60 para. 1 of the regulations). Basic training must be completed within six months of joining (§61 para. 2).
VQF: basic training within twelve months of joining or of starting the activity, followed by further training in the cycle set by the board (Art. 6 of the training concept). According to VQF, further training is required every two years.

The other SROs have their own requirements. What counts is always the current version of your SRO’s regulations; the versions cited here are listed in the sources.

New employees

Anyone newly taking on an AML-relevant role needs basic training – regardless of the further-training cycle. SROs set deadlines for this (PolyReg: six months, VQF: twelve months). For FINMA-supervised institutions, the deadline follows from the internal directives.

Set out the training frequency in your internal directives (FINMA: Art. 26 para. 2 let. e AMLO-FINMA).
As an SRO member: check the cycle and deadlines in your SRO’s current regulations.
Train new employees within the applicable deadline.
Update content after legal changes – for example after the AMLA revision of 1 October 2026.
Document every training session in a traceable way (who, when, which content).

Sources

This article provides an overview and does not constitute legal advice. The cited legislation and your SRO’s regulations are authoritative; legal provisions are paraphrased in English.

The FinReg Swiss AML training records every completion automatically – with date, content, version and test result for each person.

The training “Training records” checklist