Annual AML training completion for relevant staff
MGA.OPS.STAFF.AML_TRAINING.1 · MGA · licensing_personnel
Requirement
All employees in customer-facing, payments, AML, and senior management roles must complete annual AML/CFT training, with records retained for at least 5 years.
Source: MGA + FIAU Implementing Procedures, Chapter on Training · Audit artifact: FIAU Annual AML Return
Remediation guidance
Tag in-scope roles in HRIS and enrol them in annual AML course via LMS.
Evidence specification
| Evidence type | Connector | Spec | Acceptance criteria |
|---|---|---|---|
training_record | hr-bamboohr | {
"course_tag": "aml_annual",
"required_fields": [
"employee_id",
"role",
"completed_at"
]
} |
|
Recent evaluations (Apollo Gaming Ltd.)
✗
| When | Status | Findings |
|---|---|---|
| 5/20/2026, 11:51:33 PM | fail | 1 finding — 3 staff in scope-required roles overdue on annual AML training: 1 Payments analyst (last trained 14 … |