AML/KYC training for domiciliation center teams: program, duration, traceability

In brief

Article 11 of the Act of 18 September 2017 requires every staff member with AML file contact to complete initial and ongoing training, failing which SPF Economie inspections will flag a documentary deficiency. A structured 8-module program (~15 initial hours) with knowledge assessment and written traceability is the only way to fully meet this obligation in Belgium in 2026.

Training, an often-neglected obligation

Article 11 of the Act of 18 September 2017 requires every regulated profession to set up initial and ongoing training for all staff with AML file contact.

Yet, in SPF Economie inspections, this is one of the points where most centers show a documentary deficiency: trainings done but untraced, or sloppy trainings with generic certificates. This article offers a structured program, its traceability and calibration per firm size.

Who must be trained

Anyone who:

• Receives, validates or prepares KYC files

• Handles client mail

• Participates in monitoring or alerts

• Communicates with clients on AML aspects

• Manages AML-related invoicing

Concretely in a domiciliation center: everyone except possibly purely administrative roles (HR, pure reception).

Initial training program

Module 1 — Legal framework (2 hours)

• Act of 18 September 2017: main principles

• Belgian law vs European directives (4AMLD, 5AMLD, 6AMLD)

• RD 22 April 2024 specific to company service providers

• Role of authorities (SPF Economie, CTIF, NBB, FSMA)

Module 2 — KYC and identification (3 hours)

• Client identification (natural vs legal person)

• UBO cascade on 3 levels

• Required documents (see KYC file content)

• Remote identification methods (eID, itsme, video)

• Cross-check with official registers (BCE, UBO)

Module 3 — Risk assessment (2 hours)

• 4 dimensions: client × product × geography × channel

• Risk matrix

• Per-file risk grade

• Corresponding measures (standard, enhanced)

• See methodology

Module 4 — Sanctions and PEPs (1 hour)

• PEP definition and categories (see dedicated article)

• International sanctions lists

• Screening and fuzzy matching

• Actions on hit

Module 5 — Monitoring and red flags (3 hours)

• Article 35: ongoing monitoring

• Red flags per typology

• Alert triage

• See suspicious operations detection

• Practical cases (see our 5 concrete cases)

Module 6 — CTIF reporting (2 hours)

• When to report (reasonable suspicion)

• How to draft a useful report

• goAML platform

• Tipping-off prohibition

• Legal protections for the reporter

• See CTIF guide

Module 7 — Retention and GDPR (1 hour)

• 10-year duration

• Timestamped PDF/A format

• Articulation with GDPR

• See AML data retention

Module 8 — Sanctions and risks (1 hour)

• Sanction scale

• Cumulative publication mechanism

• Recent cases (anonymized)

• See non-compliance sanctions

Total initial training duration: ~15 hours, typically spread over 3 to 5 days.

Annual ongoing training

For already-trained staff:

• Regulatory update (new directives, RDs, case law)

• New red flags (emerging typologies: crypto, deepfakes, scams)

• Internal case feedback on files analyzed

• RegTech tool evolutions

• Practical exercises on real (anonymized) cases

Minimum duration:

• AMLCO: 4 hours/year (recommended 8 hours with external colloquiums)

• Staff: 2 hours/year

Format and organization

Option 1 — Internal in-person

The AMLCO or external consultant leads the session for the whole team. Pros: interactions, firm-context adaptation. Cons: simultaneous team mobilization.

Option 2 — Certified e-learning

External platform with video modules and quizzes. Pros: flexibility, native traceability. Cons: sometimes weak engagement without follow-up.

Option 3 — Hybrid (recommended)

E-learning for fundamentals + one annual in-person session for news and practical cases.

Knowledge assessment

Article 11 does not stop at "training" — you must prove training is effective. Methods:

• Quiz at end of each module (min score 80 %)

• Role-plays: case studies with motivated decision

• Annual evaluation: 30-minute test on fundamentals

• Individual AMLCO-staff conversations on files handled

Compliant traceability

The SPF Economie inspection will request:

Detailed, dated training program

Nominative list of staff with training dates

Certificate signed by each staff member

Evaluation score or attendance trace

Supports used (presentation, e-learning)

Annual renewal documented

If any of these 6 elements is missing, training is considered non-probative.

Frequent mistakes

Onboarding training without renewal: the law requires ongoing

Generic certificate without content: "followed an AML training" does not suffice

No assessment: you do not know if the message landed

AMLCO without dedicated training: the AMLCO must be better trained than others

No firm adaptation: too generic program

No regulatory evolution tracking

Training done but untraced in the RegTech system

No practical cases: only theory

Training by email "read this PDF": non-probative

No training for new hires before file access

How Company Belgium supports training

Company Belgium's training module provides:

• Structured program in 8 modules (in-person or e-learning)

• Supports updated quarterly with regulatory evolutions

• Integrated evaluation quizzes with retained score

• Certificates automatically generated and electronically signed

• Nominative training log with dates and scores

• Automatic reminders 30 days before annual deadline

• Anonymized practical cases from real 2024-2026 typologies

• Specialist-led quarterly webinars on news

See our 2026 RegTech landscape.

Bottom line

AML/KYC training is not a post-seminar cocktail — it is a documented legal obligation. Structured program (8 modules, ~15 initial hours), annual renewal (2-4 hours), knowledge assessment, written traceability.

The right reflex: integrate training in your RegTech framework so it is traced, current, and presentable in 5 minutes during inspection. See the 2026 checklist for full scoring.