Bridgly Education Partner
Andreas Leitner – Bridgly Education Partner for Anti-Money Laundering and Countering the Financing of Terrorism under AMLR
The European Anti-Money Laundering Regulation – Regulation (EU) 2024/1624 (AMLR) – establishes a new, directly applicable European legal framework for preventing money laundering and terrorist financing. For organisations, this involves not only new regulatory requirements but also the need to prepare employees for the new rules in good time, in clear language and with a strong practical focus.
Andreas Leitner is Bridgly’s education partner for the Anti-Money Laundering and Countering the Financing of Terrorism under AMLR.
Together, Bridgly and Andreas Leitner provide digital training that combines regulatory requirements with clear explanations and practical relevance. The e-learning courses enable employees to understand the key risks of money laundering and terrorist financing, recognise warning signs and know how to respond appropriately when concerns arise.
The training programme comprises a comprehensive 60-minute standard e-learning course on the Anti-Money Laundering Regulation, supplemented by sector-specific training modules for credit institutions and insurance undertakings.
60-Minute E-Learning Course: Anti-Money Laundering and Countering the Financing of Terrorism under AMLR
The core e-learning course provides employees with a comprehensive understanding of the prevention of money laundering and terrorist financing.
It covers more than the underlying regulatory framework. Participants learn why anti-money laundering measures matter in their day-to-day work, how risks arise and what role employees play within their organisation’s prevention framework.
The course covers:
- the fundamentals and typical stages of money laundering;
- the raising, storage, transfer and use of funds for terrorist financing;
- the Anti-Money Laundering Regulation – Regulation (EU) 2024/1624;
- Regulation (EU) 2023/1113 on transfers of funds and certain crypto-assets;
- the role of the European Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA);
- customer, product, service, transaction, delivery-channel and geographical risks;
- the business-wide risk assessment;
- internal policies, procedures and controls;
- the responsibilities of the management body, compliance function, anti-money laundering officer and employees;
- data protection, documentation and record retention;
- typical warning signs of potential money laundering;
- warning signs of potential terrorist financing; and
- the correct course of action when concerns arise.
Particular emphasis is placed on the risk-based approach. Individual characteristics or transactions are not considered in isolation. What matters is the overall picture formed by the customer, economic background, product, transaction, delivery channel and geographical links.
Employees learn a distinction that is crucial in practice:
They are not required to prove money laundering or terrorist financing themselves. Their responsibility is to recognise concerns, document them clearly and report them through the designated internal reporting channel.
The final assessment is undertaken by the anti-money laundering officer or other responsible internal function.
Recognising Money Laundering and Taking the Right Action
Effective AML e-learning must go beyond abstract knowledge of legislation.
The course therefore examines numerous warning signs that may arise in day-to-day work. These include unusual information provided by customers, opaque ownership structures, suspicious customer behaviour, unusual cash transactions, complex payment flows, payments from unknown third parties and transactions that are inconsistent with the customer’s previous profile.
It also considers sector-specific scenarios involving lending, trust business, insurance, asset management, securities trading and crowdfunding.
In relation to potential terrorist financing, the course emphasises that funds from legitimate sources and low-value amounts can also be relevant. The decisive factors are the purpose, parties, recipients, transaction patterns and wider context.
When concerns arise, employees follow a clear sequence:
Recognise. Document. Report internally. Maintain confidentiality.
Employees are not responsible for conducting investigations independently, making a final personal assessment of whether a suspicion is justified or informing the customer about an internal review.
Supplementary Module for Credit Institutions
For employees of banks and other credit institutions, the 60-minute standard course is supplemented by an approximately 10-minute e-learning module covering the specific requirements for credit institutions.
The module is based on the credit-institution-specific aspects of BaFin’s Interpretation and Application Guidance and focuses on typical risk areas within the banking sector.
In particular, it covers:
- cash transactions and evidence of the source of funds;
- property transactions;
- investment business and investor structures;
- syndicated loans;
- correspondent banking relationships;
- screening and transaction monitoring;
- trust accounts; and
- trade finance.
Employees learn why a verifiable source of funds is particularly important for cash transactions, which specific considerations apply to business relationships with investment management companies and investment funds, and why correspondent banking relationships require an in-depth understanding of the respondent institution, its business activities and its customer portfolio.
A further focus is placed on monitoring and screening. The module explains the different functions of these two instruments and the importance of complete data, appropriate scenarios, transparent thresholds and explainable system decisions.
For trust accounts and trade finance transactions, the emphasis is likewise on a risk-based assessment of the underlying structures, parties, countries, goods and payment channels.
Supplementary Module for Insurance Undertakings
An approximately 10-minute sector-specific supplementary module is also available for insurance undertakings.
In the insurance sector, the first question is which specific activity is being performed. Status as an obliged entity under anti-money laundering legislation does not automatically attach to every type of insurance business.
The e-learning module therefore covers:
- activity-based status as an obliged entity;
- life insurance and other insurance activities falling within the applicable scope;
- specific considerations relating to lending activities;
- risk assessment and organisational arrangements;
- occupational pension schemes;
- beneficial owners in particular contractual arrangements;
- assignments by way of security;
- time-value accounts and pension liability insurance;
- pension equalisation;
- the updating of customer data; and
- dealing with missing information.
Particular emphasis is placed on occupational pension schemes. The module explains the respective roles of the employer, insured person and beneficiaries, as well as the implications of privately continuing a policy for the KYC process.
Employees also learn to recognise typical triggers for updating customer information. These may include large additional contributions, premium increases, name changes, a change of policyholder, changes to the legal form of a company, returned mail or policy loans.
One Foundation Course – Targeted Sector Supplements
The training programme follows a clear structure.
The 60-minute standard e-learning course provides the general regulatory and practical foundations for preventing money laundering and terrorist financing.
The sector-specific supplementary modules build on this foundation:
Credit institutions:
60 minutes of core content + approximately 10 minutes covering specific considerations for credit institutions.
Insurance undertakings:
60 minutes of core content + approximately 10 minutes covering specific considerations for insurance undertakings.
This avoids repeating the same general content in every sector-specific course. At the same time, employees receive precisely the additional information relevant to their sector, products and typical business processes.
Practical AMLR Training with Bridgly and Andreas Leitner
Effective anti-money laundering training requires more than teaching individual statutory provisions. Employees need to understand why a situation may be relevant, what they should look out for and what is expected of them in a specific case.
This is precisely what the training programme is designed to achieve.
As Bridgly’s education partner for the prevention of money laundering and terrorist financing under the AMLR, Andreas Leitner combines regulatory expertise with a practical approach tailored to digital learning formats.
The result is a series of e-learning courses that explain the complex requirements of anti-money laundering compliance in a structured manner and provide employees with clear guidance for their day-to-day work.