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An AML training register that shows what your team is ready to do
A list of certificates records the past. A useful training register also reveals gaps, role changes and the follow-up each employee needs.
A new customer-onboarding employee has an AML certificate, but it came from a previous role with very different responsibilities. Another employee attended the company’s latest briefing but has not completed its assessment. A third understands the procedure yet missed an update while on leave.
A register that marks all three simply “trained” loses the distinctions that matter. The purpose of an AML training register is to connect a person, a role and a learning need with what actually happened.
What belongs in the register?
The register is an index, not a place to paste every slide, certificate and test response. It should help a reviewer locate the underlying evidence and understand the current position without guessing.
Articles 21 and 22 of Cabinet Resolution 134 of 2025 place periodic and ongoing documented training within the entity’s controls. They do not prescribe the exact spreadsheet below. This is a practical template to adapt to the business and any specific supervisory requirements.
Field | What it records | Why it matters |
|---|---|---|
Employee reference and name | A stable identifier and the person’s name | Distinguishes people with similar names |
Role and relevant duties | Responsibilities at the time of training | Explains why this learning was required |
Learning need | Induction, refresher, role change or procedure update | Connects training to a reason |
Course or session and version | The material actually delivered | Distinguishes changed content with the same title |
Language and delivery method | How the employee received it | Helps explain accessibility and participation |
Assigned and completed dates | Planned activity separately from actual completion | Avoids presenting a booking as attendance |
Outcome | Attendance, assessment result or other appropriate check | States what was demonstrated |
Evidence reference | Location of the certificate, attendance or assessment record | Makes the entry verifiable |
Follow-up, owner and review date | Outstanding action and responsibility | Keeps incomplete learning visible |
One example, followed through
Suppose, hypothetically, a receptionist moves into customer onboarding. The employee’s earlier awareness course remains a valid historical record. The new role, however, includes gathering ownership information and routing incomplete files.
The register should retain the earlier course and add the new learning need. After a procedure briefing, it can record participation. If a case exercise then shows confusion about when to escalate, that becomes follow-up rather than a silently overwritten “pass”.
Once the follow-up is completed, the record can show what changed and when. A reviewer can understand the sequence without assuming that every activity happened on the first course date.
Completion dates are not expiry dates
A completion date records an event. A review date records when the business intends to reconsider a need. A provider’s certificate-validity date, where one exists, is another distinct fact.
Collapsing these into one “expiry” column can create misleading conclusions. An approaching internal refresher does not mean a past course never happened. Equally, an unexpired certificate does not establish that someone understands a procedure introduced yesterday.
A register becomes more useful when these dates have clear meanings and reminders follow the company’s actual programme rather than an invented universal annual expiry.
How much evidence is enough?
The right evidence depends on the claim. Attendance supports participation. An assessment supports a result on the questions used. A supervisor’s recorded case review can support a narrower practical observation. None should be presented as more than it demonstrates.
The register generally does not need passport copies, unrelated medical details or the full content of suspicious-activity files. A controlled employee reference and restricted evidence links are usually a better design than accumulating personal data in a widely shared workbook.
The separate attendance-sheet guide explains how to capture session participation without confusing it with a pass.
Keeping the register usable
A register needs an owner and a reliable update point: when learning is assigned, completed or reviewed. It should also make gaps visible. An overdue activity, an unanswered invitation and a completed course are not the same state.
Over time, the pattern can improve the training itself. If several people struggle with the same case, the issue may be the explanation or procedure rather than isolated employee effort. The record then becomes a tool for management, not merely a document produced for inspection.
Questions we are asked
Short answers on the points readers raise most about this topic.
- How should a new joiner with no completed training appear?
- Show the assigned learning, due date, current status and responsible person. Do not omit the employee until completion; doing so hides the gap the register is supposed to reveal.
- Should the register contain Emirates ID numbers?
- Use only the personal data genuinely needed for identification and record management. An internal employee reference may be sufficient. Any additional identifier needs an appropriate purpose, access controls and retention arrangements.
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