Knowledge

AML training in-house or external? Criteria for choosing a provider

Both are permitted, as long as the training is adequate and meets the requirements of your supervisor. What matters are the SRO’s requirements for external and in-house training, the currency and fit of the content, a learning check, auditable records and your own effort. A combination often makes sense: external fundamentals plus in-house training on your own directives.

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

What regulation requires

The Act requires adequate training (Art. 8 and 8d AMLA) but does not say who provides it. For FINMA-supervised institutions, training must cover the aspects relevant to the employees concerned (Art. 27 para. 2 AMLO-FINMA) – in other words, it must be tailored to their role. SROs may set stricter requirements:

VQF: the AML officer and deputy must in principle be trained externally; other employees may be trained in-house if the training is equivalent (Art. 9 of the training concept). Computer-based learning programmes are expressly provided for (Art. 4).
PolyReg: own basic training only with authorisation and an approved training concept; external further training is recognised upon prior request (§61). PolyReg additionally requires in-house training on the member’s own measures and directives (§60 para. 2).

Criteria for the choice

Recognition: will your SRO recognise the training? If in doubt, ask in advance.
Matching legal basis: FINMA version (AMLA, AMLO-FINMA, CDB 20 for banks) or SRO version (AMLA, AMLO, SRO regulations).
Currency: who updates the content after legal changes such as the AMLA revision 2026 – and how quickly?
Practical relevance: cases and examples from the Swiss environment and from your industry.
Learning check: a test or another assessment, not just attendance.
Records: can you show, for each person, who completed what and when – and are the records quickly available for the audit?
Language and access: the languages of your team, flexible participation, including for employees joining during the year.
Effort: creating, delivering, following up and archiving for an in-house solution; cost and coordination for an external solution.

In-house training: strengths and effort

In-house training can be very close to your own directives and cases. It requires someone with sound expertise to create the content, keep it up to date, track participation and keep the records – and, where applicable, recognition by the SRO.

External training: strengths and limits

External providers bring prepared, continuously updated content and often standardised records. They do not know your internal directives in detail; these still need to be taught in-house.

Know the requirements of your supervisor or SRO for external and in-house training.
The legal basis of the training matches your regulation.
Responsibility for updates is clear.
A learning check and auditable records per person are in place.
Your own directives are additionally taught in-house.

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