Knowledge

What must AML training records contain for an audit?

The Act and the ordinances do not contain an exhaustive list. However, the training obligation can only be audited if it is clear who was trained, when and on which content. Robust training records therefore contain, for each person, the date, the content and its version, the training format and a learning check – together with the training materials.

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

Legal starting point

The training obligation follows from Art. 8 AMLA (for advisors Art. 8d AMLA) and, for FINMA-supervised institutions, from Art. 27 AMLO-FINMA. The documentation obligation under Art. 7 AMLA, by contrast, concerns transactions and the clarifications made on business relationships – not training. There is no specific provision on what training records must look like.

What SROs want to see in an audit

VQF: for in-house training, the training materials including the attendance list must be presented to the auditor (Art. 10 para. 3 of the training concept). In-house training must also be declared in the annual self-declaration (Art. 9 para. 3).
PolyReg: members running their own basic training need an approved written training concept; the audit bodies check and document compliance with it (§61 para. 3 of the regulations).

FINMA-supervised institutions set out the principles of their training in their internal directives (Art. 26 para. 2 let. e AMLO-FINMA). Training records show that these requirements are being implemented.

“Training records” checklist

The following information has proven useful. It is derived from the obligations above and is not a statutory list:

Name and role of each person trained.
Completion date (for multi-part training: per part).
Content and its version: topics or modules, version or date of the materials.
Legal basis of the training, e.g. AMLA and AMLO-FINMA, or AMLA, AMLO and SRO regulations.
Format and provider: in-house, external, e-learning; for SRO members, where applicable, recognition by the SRO.
Learning check: test with result or another form of assessment.
Overview of who has not yet been trained or not on time – especially new employees.
Training materials and attendance lists archived and quickly available for the audit.

The Act does not set a specific retention period for training records. Set out in your internal directives how long you keep them.

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