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AML in 90 Minutes: What Every Professional Should Know
in Compliance & RegulationAbout this course
1. Aim of the Course
The aim of this course is to provide a clear, practical introduction to how Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) is applied in organisations through a risk-based approach (RBA), how to recognise and interpret common warning signs (“Red Flags”), and how governance arrangements allocate accountability for effective compliance. This course is designed to support consistent, defensible decision-making, appropriate documentation, and timely escalation of concerns in professional settings.
2. Learning objectives
By the end of this module, you should be able to:
- Explain the risk-based approach (RBA) to AML/CFT at a high level and why it underpins modern compliance.
- Identify common red flags in customer behaviour, transactional activity, and documentation.
- Describe governance and accountability in AML/CFT (key roles, responsibilities, and escalation pathways).
- Apply these concepts to short scenarios to select appropriate next steps (e.g., proceed, request evidence, escalate).
On successfully completing the module you will be able to:
Subject-specific knowledge:
- Explain what “risk-based approach” means in AML/CFT and distinguish inherent risk vs. residual risk at a basic level.
- Identify the main components of an AML/CFT RBA (e.g., risk identification, risk assessment, controls, monitoring, and review).
- Define what an AML “red flag” is and differentiate indicators from evidence.
- Describe core governance concepts, including accountability, oversight, independence, and effective escalation, including typical role expectations.
Practical and transferable skills:
- Apply structured thinking to assess whether activity appears inconsistent with expected patterns given a basic customer/context profile.
- Record observations clearly using neutral, factual language and minimum documentation standards (what happened, why it matters, what was checked, what is outstanding).
- Select proportionate actions aligned to the RBA (e.g., request clarification, seek additional documentation, increase monitoring, escalate).
- Follow escalation pathways appropriately, maintaining confidentiality and avoiding inappropriate disclosure.
3. Core topics:
- High-level risk-based approach
- Common red flags.
- AML/CFT Governance and accountability.
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After completing this learning experience, you will be able to:
- Describe the purpose of the Three Lines of Defence model in an AML control environment.
- Explain the roles and responsibilities of each line in managing and overseeing AML controls.
- Distinguish between operational ownership of controls, compliance oversight and challenge, and independent assurance.
- Map common AML activities to the appropriate line of defence.
- Describe how the three lines interact through escalation, reporting, and assurance.
Module 1 - Governance & Accountability Assignment
Task Description:
Read the assigned case study carefully. You are required to use the information contained in the case study to answer 10 multiple-choice questions.
Specifically:
- Read the case study in full.
- Answer the 10 multiple-choice questions that follow.
- For each question, select one correct answer. Each question has only one correct option. Your task is simply to identify and select that correct answer based on the case study.
The questions will assess your ability to:
- Describe the purpose of the Three Lines of Defence model in an AML control environment.
- Explain the roles and responsibilities of each line in managing and overseeing AML controls.
- Distinguish between operational ownership of controls, compliance oversight and challenge, and independent assurance.
- Map common AML activities to the appropriate line of defence.
- Describe how the three lines interact through escalation, reporting, and assurance.
After completing this learning experience, you will be able to:
- Explain what the risk-based approach means in AML and CFT.
- Describe why financial crime risk is not uniform and why controls must be proportionate to risk.
- Distinguish between inherent risk, the effectiveness of controls, and residual risk.
- Explain the role of risk appetite and senior governance in setting boundaries and control expectations.
- Identify key risk drivers, including customer risk, product and service risk, geographic risk, and delivery channel risk.
- Describe how risk level influences due diligence measures, monitoring intensity, and escalation expectations.
Read the assigned case study carefully. You are required to use the information contained in the case study to answer 10 multiple-choice questions.
Task:
Read the case study in full.
Answer the 10 multiple-choice questions that follow.
For each question, select one correct answer.
Each question has only one correct option. Your task is simply to identify and select that correct answer based on the case study.
The questions assess your ability to:
Identify relevant facts in the case study.
Recognise key AML/CFT risk indicators and red flags.
Apply basic risk-based reasoning to the scenario presented.
Submission instructions:
All 10 questions must be answered.
Responses must be based strictly on the case study provided.
Case summary:
Entity profile: Corporate customer applying to a VARA licensed custodial exchange in Dubai
Customer: Al Noor General Trading FZE
Onboarding channel: Remote, submitted via paid introducer
Declared business purpose: Treasury management and overseas supplier payments in USDT
Declared monthly turnover through platform: AED 5,000,000
Expected activity profile: Two to four USDT transfers per month to named overseas suppliers
Risk rating at onboarding: Medium
Notes: Requested Rapid Treasury access immediately and asked for higher withdrawal limits during onboarding
Key risk drivers at onboarding
Customer risk: Layered ownership with offshore entities and incomplete beneficial ownership evidence
Product and service risk: Rapid Treasury enables fast AED to USDT conversion and external wallet withdrawals
Jurisdiction risk: Stated supplier corridors include higher risk geographies under the firm’s internal risk matrix
Delivery channel risk: Non face to face onboarding and reliance on introducer documentation pack
Control quality signals: PEP screening possible match closed with minimal documented rationale and generic source of funds narrative
Transaction and behaviour history (10 days):
Day 1: Account activated with Rapid Treasury enabled
Day 3: AED 9,800,000 deposit split into three tranches just under AED 3,300,000 from three different UAE accounts not disclosed as counterparties
Day 3: AED converted to USDT within one hour and withdrawn to two external wallets
Day 5: AED 12,400,000 deposit converted and withdrawn same day to a new external wallet
Day 8: USDT received from an external wallet, converted back to AED, then paid out locally to a third party described as consulting services
Day 10: Customer requests increased withdrawal limits and states delays will cause supplier penalties
Day 10: Customer insists on using specific external wallets rather than supplier wallets
Day 10: Customer provides invoices that do not match counterparties and show repeated formatting anomalies
On chain and monitoring signals
Day 3 to Day 10: Two destination wallets show exposure to a mixing service and a cluster associated with prior fraud reports
Day 8: Inbound wallet shows links to multiple newly created addresses with short transaction histories
Day 10: Case opened by first line due to rapid in and out pattern and wallet risk indicators but marked pending information while documents are requested
Day 10: Informal MLRO awareness but no formal evidence pack escalation recorded
After completing this learning experience, you will be able to:
- Define what a red flag is in Anti-Money Laundering and Counter-Terrorist Financing
- Identify common red flags across customers and transactions
- Explain why a red flag is a trigger for action, not a conclusion
- Describe the expected response: document, review, escalate, and report where required
Module 3 – Common Red Flags in AML/CTF
Task Description:
Read the assigned case study carefully. You are required to use the information contained in the case study to answer 10 multiple-choice questions.
Specifically:
- Read the case study in full.
- Answer the 10 multiple-choice questions that follow.
- For each question, select one correct answer. Each question has only one correct option. Your task is simply to identify and select that correct answer based on the case study.
The questions will assess your ability to:
- Define what a red flag is in Anti-Money Laundering and Counter-Terrorist Financing
- Identify common red flags across customers and transactions
- Explain why a red flag is a trigger for action, not a conclusion
- Describe the expected response: document, review, escalate, and report where required
