Is AML training mandatory for your staff?

Yes. The law requires obliged entities to adopt measures so that their employees and managers know the requirements of anti-money laundering prevention (art. 29), which takes the form of an annual training plan, approved by the internal control body, with accredited participation in specific courses.

What the rule does not impose is a format: it does not require outsourcing the training, nor official approval of the programmes. What an inspection does expect is to see the plan, the contents and the proof of who attended — with certificates that is simple; with "we told them in a meeting", it is not.

Three practical notes:

• Training must be proportionate to the role: the salesperson who identifies customers does not need the same content as whoever runs the accounts.
• Micro-companies exempt from the exam (fewer than 10 employees and ≤ €2 million, letters i-u) are also exempt from the formal plan — but their staff must still detect and report suspicious activity, so a short annual session remains the best insurance policy.
• It is the natural companion of the annual exam: the same expert who assesses your system can close the training gap their report would otherwise flag.

PBK delivers general and sector-specific courses, in person or remotely, with a certificate valid for inspection purposes.

Legal basis:

• Art. 29 of Ley 10/2010
• Art. 39 of RD 304/2014 (annual training plan)
• Art. 31.1 of RD 304/2014 (size exemption)

Reviewed: August 2026 · PBK Asesores — external experts in AML/CTF before SEPBLAC since 2010, more than 900 exams performed.

Does this affect you? We will confirm it in a two-minute call → Contact · +34 91 110 28 29

Related:

• The external expert exam
• Size exemptions
• Penalties under Ley 10/2010
• All frequently asked questions