Regulation 24 of the Money Laundering Regulations 2017 requires a practice to make its relevant employees and agents aware of the law on money laundering, terrorist financing and proliferation financing, and to train them regularly to recognise and deal with suspicious situations. The firm must keep a written record of the training. The Regulations do not fix a frequency, but HMRC expects at least annual training for the businesses it supervises.

Who has to be trained?

Regulation 24(2) defines a relevant employee as one whose work is relevant to the firm’s compliance with any requirement of the Regulations, or is otherwise capable of contributing to identifying or mitigating the firm’s money laundering, terrorist financing or proliferation financing risks, or to preventing or detecting them. Since 2020, regulation 24(1) has extended the duty to agents the firm uses whose work is of the same kind, which in a practice usually means subcontract bookkeepers, payroll bureaux and freelance tax staff.

In an accountancy practice, that covers almost everyone who handles client work: partners, managers, accounts and tax staff, bookkeepers, payroll staff, and whoever runs onboarding checks or the client money account. HMRC’s guidance says the definition applies regardless of seniority and includes administrative, operational, client facing, supervisory and compliance roles. ICAEW’s smaller practices helpsheet suggests a receptionist may fall outside it, depending on the scope of the role.

There is a wider layer too. HMRC says all staff, not only relevant employees, must be made aware of who the nominated officer is, and should know how and when to make an internal report and how to avoid tipping off. That reflects the fact that the reporting duty in section 330 of the Proceeds of Crime Act 2002 falls on individuals.

A sole practitioner with no employees and no agents has nobody to train, but still needs to keep their own knowledge current. ICAEW’s summary for sole practitioners says they must make sure they are familiar with the Regulations to ensure continuing compliance.

What must the training cover?

Regulation 24(1)(a) sets two strands:

  • Awareness of the law on money laundering, terrorist financing and proliferation financing, and of the data protection requirements relevant to implementing the Regulations.
  • Regular training in how to recognise and deal with transactions, activities or situations that may be related to money laundering, terrorist financing or proliferation financing.

HMRC’s suggested starting point covers the Regulations, HMRC guidance, the risks facing the business, the vulnerabilities of its services and delivery channels, and its own policies, controls and procedures. ICAEW adds that training should explain how the law applies to the firm and its procedures on customer due diligence, internal reporting, record keeping and data protection, and should include red flags.

For a practice, useful red flags to cover include clients who resist identity checks, unexplained funds passing through the client account, requests for complex structures with no clear purpose, incomplete records engagements and tax that appears to be deliberately understated. Staff also need to understand that there is no minimum amount, and that the line between legitimate planning and evasion is explained in tax avoidance vs tax evasion.

How often should training be given?

Regulation 24(1)(a)(ii) says only that training must be given “regularly”. Regulation 24(3) requires the firm, in deciding what is appropriate, to take account of the nature and size of the business and the nature and extent of its risks, and allows it to take account of Treasury approved guidance.

HMRC’s guidance for the businesses it supervises is more specific:

  • relevant employees should be trained at the start of their employment, and agents when they are taken on;
  • HMRC expects training at least annually, and more often in higher risk businesses;
  • training needs should be reassessed when competency problems show up, new risks emerge, the Regulations or internal procedures change, staff change role, or new services or technology are introduced.

Most accountancy practices are supervised by a professional body rather than HMRC, but an annual refresher with prompt updates after significant change is a defensible approach, and the firm wide risk assessment should explain the frequency chosen. Significant changes in 2026 include the amendments to the Regulations in force from 30 June 2026.

What does the training record need to show?

Regulation 24(1)(b) requires a written record of the measures taken and, in particular, of the training given to relevant employees and agents. HMRC expects the record to show who was trained, the date, the content and format, and any assessment of its effectiveness. ICAEW’s minimum is a summary of content, the date, the individuals who received it and the results of any assessments.

Field Example entry
Name and role Payroll assistant
Date Session date, plus induction date for new joiners
Content Internal reporting, tipping off, red flags in payroll work, 2026 changes
Format and provider Workshop led by the MLRO, or a named online course
Assessment Test score, or a note that questions were answered in the session
Follow up Any retraining required and its date

Keeping this alongside the firm’s other AML records makes it easy to produce on a monitoring visit; see AML record keeping. ICAEW lists training of all relevant employees among the points its reviewers check on site.

Does screening count as training?

No, but the two are linked. Regulation 21(1)(b) requires a firm, where appropriate to its size and nature, to screen relevant employees before appointment and during it. Screening means assessing their skills, knowledge and expertise and their conduct and integrity. ICAEW suggests knowledge can be assessed through a recorded test, so a well designed training assessment can serve both purposes.

What happens if staff are not trained?

There are consequences for the firm and, indirectly, for the individuals:

  • Training is a “relevant requirement” under paragraph 5 of Schedule 6, so a failure can lead to civil sanctions or, under regulation 86, a criminal offence carrying up to two years on indictment. Regulation 86(3) gives a defence where the firm took all reasonable steps and exercised all due diligence.
  • Section 330(7) of the Proceeds of Crime Act 2002 gives an employee a defence to the failure to disclose offence where they did not actually know or suspect money laundering and their employer had not provided the training specified by order. An untrained employee who missed obvious warning signs may escape liability, but the firm has still failed in its duty and the suspicion has gone unreported.

Using an external provider does not shift the obligation. HMRC’s guidance says the firm remains responsible for making sure the training is comprehensive, relevant and tailored to its business. It also notes that procedures manuals supplement training but are not generally written as training material.

What might a year’s programme look like?

Illustration only. A practice with 15 staff and two subcontract bookkeepers sets out its approach in its procedures manual. New joiners complete an induction session with the MLRO in their first week, covering the reporting route, tipping off and the firm’s identity checks. Every autumn all client staff and both subcontractors attend a one hour workshop, followed by a ten question test with a pass mark set by the MLRO. The payroll team gets an extra session on payroll fraud indicators because the risk assessment rates payroll as the firm’s highest risk service. When the Regulations changed in 2026, the MLRO circulated a summary and ran a short briefing within a month. Each step is logged in a training register with dates, attendees, content and test results.

What are the common mistakes?

  • Training partners and qualified staff but forgetting subcontractors and agents.
  • Using a generic online module with nothing about the firm’s own procedures or services.
  • No record, or a record showing attendance but not content or assessment.
  • Letting the cycle slip after a busy January, with no catch up for absentees.
  • Not briefing staff after a change in the law, procedures or the services offered.

Solar Protect runs fee protection schemes for accountancy and bookkeeping practices. See how our accountant schemes work or read fee protection schemes for accountants.

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Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.