• The primary objective of the programme is to develop participants who are able to move beyond simply understanding AML terminology and compliance requirements and who can apply AML principles practically within their working environment.

On completion of the programme, participants should be able to:

• Explain money laundering, terrorist financing and related financial crime risks.
• Understand the key components of the AML regulatory framework and the responsibilities of organisations and employees.
• Understand and apply a risk-based approach to AML compliance.
• Conduct appropriate Customer Due Diligence (CDD).

Identify and understand beneficial ownership structures.

• Recognise circumstances requiring Enhanced Due Diligence (EDD).
• Assess and document client and business relationship risks.
• Understand screening requirements relating to sanctions, targeted financial sanctions, PEPs and other relevant risk indicators.
• Identify unusual and potentially suspicious transactions or behaviour.
• Investigate and escalate AML concerns appropriately.
• Understand applicable regulatory reporting requirements.
• Recognise emerging and more sophisticated money laundering methods.
• Apply AML knowledge to complex, integrated case studies
  
  

SESSION 1: AML FUNDAMENTALS – UNDERSTANDING MONEY LAUNDERING & FINANCIAL CRIME
Purpose
The first session establishes the foundation for the entire programme.
Before participants can effectively implement AML controls, they need to understand what money laundering is, why criminals need to launder proceeds and how legitimate organisations and professional services may be exploited in the process.

Key Topics
The session will cover:

• Understanding money laundering.
• Proceeds of unlawful activities.
• Predicate offences and financial crime.
• The traditional stages of money laundering:

• Placement;
• Layering; and
• Integration.

• Why modern laundering schemes may not follow the traditional three-stage model.
• Introduction to terrorist financing.
• Introduction to proliferation financing.
• Differences between money laundering and terrorist financing.
• How legitimate businesses and professionals can become facilitators of financial crime.
• Use of companies, trusts and other legal structures.
• Nominees and intermediaries.
• Cash-intensive businesses.
• Property and asset transactions.
• Cross-border movement of funds.
• Common AML terminology.
• Introduction to AML red flags.
• Consequences of inadequate AML controls.

Practical Application

Participants will work through a practical scenario following the movement of funds from the original criminal activity through various transactions and structures until the funds appear to have a legitimate source.

Learning Outcome
Participants should be able to explain the basic mechanics of money laundering and identify common indicators that a transaction, client or business relationship may present a money laundering risk.

SESSION 2: THE AML REGULATORY FRAMEWORK & COMPLIANCE RESPONSIBILITIES
Purpose
The second session moves from understanding financial crime to understanding what organisations and individuals are required to do to prevent, detect and respond to it.
For South African participants, particular emphasis will be placed on the Financial Intelligence Centre Act (FICA), the role of the Financial Intelligence Centre (FIC) and the risk-based approach to AML/CFT/CPF compliance.

Key Topics
The session will include:

• Overview of the South African AML/CFT/CPF regulatory environment.
• The Financial Intelligence Centre Act.
• The role and powers of the Financial Intelligence Centre.
• Accountable institutions.
• Supervisory bodies.
• Understanding the risk-based approach.
• Institutional risk assessments.
• Risk Management and Compliance Programmes (RMCPs).
• Governance and management responsibilities.
• The role of the compliance function.
• Employee responsibilities.
• Internal AML policies, procedures and controls.
• Record-keeping requirements.
• Training requirements.
• Regulatory inspections and information requests.
• Consequences of non-compliance.
• Administrative sanctions.
• Introduction to FATF and international AML standards.
• The relationship between legislation, regulatory requirements, internal policies and risk-management decisions.

Practical Application
Participants will be provided with a fictional organisation and required to identify its principal AML obligations, key responsible persons and the controls that should be implemented.

Learning Outcome
Participants should understand how AML legislation translates into practical responsibilities, policies, procedures and controls within an organisation.

SESSION 3: KNOW YOUR CLIENT – CDD, BENEFICIAL OWNERSHIP & SCREENING
Purpose
Session 3 introduces participants to one of the most important practical components of an effective AML framework: understanding who the organisation is actually doing business with.
Participants will progress from simply collecting identification documents to understanding the client, the purpose of the relationship, the persons exercising ownership or control and the potential risks associated with the relationship.

Key Topics
Customer Due Diligence

• Purpose of Customer Due Diligence.
• When CDD should be conducted.
• Establishing and verifying identity.
• Natural persons.
• Companies and other legal persons.
• Partnerships.
• Trusts and similar arrangements.
• Persons acting on behalf of another.
• Establishing authority to act.
• Understanding the nature and purpose of the business relationship.
• Source of funds.
• Source of wealth.
• Ongoing due diligence.
• Updating client information.
• Dealing with unreliable or outdated information.
• Inability to complete CDD.

Beneficial Ownership

• Understanding beneficial ownership.
• Legal ownership versus beneficial ownership.
• Ownership and control.
• Looking beyond the shareholder register.
• Multi-layered corporate structures.
• Controlling persons.
• Beneficial ownership of trusts.
• Nominee arrangements.
• Warning signs associated with concealed ownership.

Screening
Participants will also be introduced to screening relating to:

• Targeted Financial Sanctions.
• Broader sanctions exposure.
• Foreign and domestic Politically Exposed Persons.
• Prominent influential persons, where relevant.
• Adverse media.
• High-risk jurisdictions.
• Other relevant client risk information.

Practical Application
Participants will analyse a fictional ownership structure involving companies, shareholders and a trust and determine who the relevant beneficial owners are and what additional information should be obtained.

Learning Outcome
Participants should be able to perform practical CDD, identify beneficial ownership and recognise circumstances requiring additional investigation.

SESSION 4: RISK-BASED AML – CLIENT RISK ASSESSMENT, EDD & HIGH-RISK RELATIONSHIPS
Purpose

Session 4 develops participants' ability to move from collecting information to analysing that information and making appropriate risk decisions.

Participants will learn that a risk-based AML framework does not require every client to be treated identically. Controls should be proportionate to the risks presented.

Key Topics
The session will examine:

• Client risk.
• Product and service risk.
• Transaction risk.
• Delivery-channel risk.
• Geographic risk.
• Industry and sector risk.
• Ownership and structural complexity.
• Risk-rating methodologies.
• Low, medium and high-risk classifications.
• Quantitative and qualitative risk assessments.
• Weighting of risk factors.
• Application of professional judgement.
• Documenting risk decisions.
• Risk appetite.
• Identifying unacceptable risk.

Enhanced Due Diligence
Participants will examine circumstances that may trigger EDD, including:

• High-risk clients.
• PEP relationships.
• Higher-risk jurisdictions.
• Complex ownership structures.
• Unusual transaction patterns.
• Source of wealth concerns.
• Source of funds concerns.
• Independent corroboration of information.
• Management approval.
• Increased monitoring.
• Increased review frequency.

Practical Application
Participants will be provided with several fictional clients presenting different risk profiles. They will be required to assess and risk-rate each client, determine whether EDD is necessary and justify their conclusions.

Learning Outcome
Participants should be able to make and document defensible AML risk decisions rather than relying solely on a compliance checklist.

SESSION 5: DETECTING, INVESTIGATING & REPORTING SUSPICIOUS ACTIVITY
Purpose

Session 5 develops the practical skills necessary to recognise when client behaviour or transactions require further investigation, escalation or regulatory reporting.

A central theme of the session will be understanding that unusual activity is not automatically suspicious. Participants must develop the ability to investigate unusual activity and determine whether a reasonable and credible explanation exists.

Key Topics
Participants will examine red flags relating to:

• Customer behaviour.
• Identification and CDD information.
• Beneficial ownership.
• Transaction patterns.
• Cash transactions.
• Third-party payments.
• Rapid movement of funds.
• International transfers.
• Complex transactions without apparent commercial rationale.
• Property transactions.
• Trust and corporate structures.
• Attempts to avoid CDD.
• Reluctance to provide documentation.
• Transactions inconsistent with the known client profile.

The session will also address:

• Transaction monitoring.
• Investigating unusual activity.
• Gathering additional information.
• Reviewing CDD records.
• Transaction analysis.
• Open-source information.
• Adverse-media searches.
• Documenting findings.
• Internal escalation.
• Confidentiality.
• Avoiding tipping-off.
• Regulatory reporting obligations.
• Different types of FIC reports and their purposes.
• Reporting versus terminating a business relationship.
• Post-reporting considerations.

Practical Application
Participants will receive a fictional client file containing CDD documentation, transaction information, communications, ownership information, screening results and adverse-media information.

They will determine whether the activity is unusual or suspicious, what further investigation is required, whether escalation or reporting is potentially required and whether the relationship should continue.

Learning Outcome
Participants should be able to recognise, investigate, document and appropriately escalate potential suspicious activity.

SESSION 6: ADVANCED AML IN PRACTICE – COMPLEX CASES, SANCTIONS & EMERGING RISKS
Purpose

The final session brings together the knowledge and skills developed throughout the programme and applies them to complex, realistic AML scenarios.

The emphasis will be on problem-solving, judgement and the ability to integrate multiple AML considerations simultaneously.

Key Topics
Advanced Money Laundering Risks

• Shell and front companies.
• Layered ownership structures.
• Nominee shareholders and directors.
• Trust structures.
• Trade-based money laundering.
• Property and high-value assets.
• Professional intermediaries.
• Third-party payments.
• Cross-border structures.
• Informal value-transfer mechanisms.
• Digital assets and crypto-related risks.

Sanctions and Targeted Financial Sanctions

• Understanding sanctions risk.
• Targeted Financial Sanctions.
• Screening clients and beneficial owners.
• False positives.
• Escalation procedures.
• Freezing obligations where applicable.
• Reporting requirements.
• Documentation.
• Ongoing screening.

Emerging AML Risks

• Artificial intelligence and financial crime.
• Deepfakes.
• Identity fraud.
• Synthetic identities.
• Digital onboarding risks.
• Crypto assets.
• Money mule networks.
• Cyber-enabled fraud and money laundering.
• Use of open-source intelligence in AML investigations.

Final Integrated Case Study

Participants will work through a complex scenario involving a South African entity, foreign ownership, a trust structure, a PEP connection, adverse-media information, third-party payments, a higher-risk jurisdiction and a potential sanctions-screening match.

Participants will be required to determine:
1. Who the client is.
2. Who the beneficial owners are.
3. What AML risk indicators exist.
4. What additional CDD is required.
5. What screening should be performed.
6. Whether EDD is required.
7. What source-of-funds or source-of-wealth evidence is necessary.
8. Whether the activity is potentially suspicious.
9. Whether regulatory reporting may be required.
10. Whether the business relationship can continue.
11. What information and decisions should be documented.

Learning Outcome
Participants should be able to bring together CDD, beneficial ownership, screening, risk assessment, EDD, transaction monitoring, investigation and reporting principles to make defensible decisions in complex AML scenarios.

Proposed Delivery Schedule
The programme can be delivered over approximately five months as follows:
Period Session Duration
Month 1 Session 1 – AML Fundamentals 2 Hours
Month 1 Session 2 – Regulatory Framework & Responsibilities 2 Hours
Month 2 Session 3 – CDD, Beneficial Ownership & Screening 2 Hours
Month 3 Session 4 – Risk Assessment & EDD 2 Hours
Month 4 Session 5 – Suspicious Activity & Reporting 2 Hours
Month 5 Session 6 – Advanced AML & Integrated Case Study 2 Hours
Total 6 Sessions 12 Hours

Training Methodology
The programme will adopt an interactive and practical learning methodology.

Training will not focus solely on legislation or theoretical compliance requirements. Participants will continually be required to consider how AML requirements should be applied in practical situations.

The methodology may include:

• Facilitated presentations.
• Practical examples.
• Real-world AML scenarios.
• Case studies.
• Group discussions.
• Client risk-rating exercises.
• Beneficial-ownership exercises.
• Red-flag identification.
• Transaction analysis.
• Screening scenarios.
• Suspicious-activity assessments.
• Knowledge assessments.
• Workplace application activities.

Workplace Application Between Sessions
To reinforce the progressive nature of the programme, participants should complete a short practical application activity between sessions.
Examples could include:

• After Session 1: Identify potential money laundering risks within a fictional or actual business environment.
• After Session 2: Review an AML policy or RMCP and identify potential control gaps.
• After Session 3: Complete a CDD and beneficial-ownership exercise.
• After Session 4: Complete and document a client risk assessment.
• After Session 5: Analyse a suspicious-activity scenario and prepare an internal escalation assessment.

These activities will reinforce the learning and prepare participants for the final integrated case study.

Assessment Approach
To measure both knowledge and practical application, the programme can incorporate:

• Short knowledge assessments after individual sessions.
• Scenario-based questions.
• Practical exercises.
• Workplace application activities.
• Participation in case-study discussions.
• A final integrated AML case study and/or assessment.

The emphasis should be on demonstrating the participant's ability to apply AML principles, rather than merely recalling legislative provisions.

9.Expected Programme Outcomes

At the conclusion of the programme, participants should have progressed through the complete practical AML journey:
Understand the crime → Understand the regulatory obligations → Know the client → Identify the beneficial owner → Assess the risk → Apply appropriate due diligence → Monitor the relationship → Identify suspicious activity → Investigate and escalate → Report where required → Manage complex AML risks.

The programme is therefore intended to develop more than regulatory awareness. Its objective is to develop practical AML capability, professional judgement and confidence in dealing with increasingly complex financial crime risks.