| Obligation | Basis | What it means in practice |
|---|---|---|
| Obliged entities | Article 5 of the Law | Financial institutions, accountants, lawyers, notaries, other non-banking entities and organisers of games of chance |
| At least 2 trainings a year | Article 12(1)(12) and Article 68(14) | An annual training plan and at least two trainings for employees during the year |
| Evidence of training | Supervision by the FIU and other supervisory bodies | Certificates of participation, attendance lists, programme and materials for each training |
Who is obliged to provide training
Article 5 of the Law lists the obliged entities that must apply anti-money laundering and counter-terrorist financing measures, including training their staff:
- financial institutions and their subsidiaries and branches (banks, savings houses, insurance and brokerage companies, leasing and financial companies, exchange offices and others);
- accountants, lawyers, notaries and other non-banking entities;
- organisers of games of chance.
How many trainings a year are required
Under Article 12(1)(12) and Article 68(14) of the Law, obliged entities must provide at least two trainings a year for their employees on the prevention of money laundering and financing of terrorism. It is good practice to plan them in an annual training plan and spread them across the year, for example one in each half.
What the training should cover
Training should help employees recognise risks and apply the measures correctly in their daily work. The most common topics are:
- the duties and activities of the authorised person, their deputy and the AML/CFT department;
- money laundering and terrorist financing risk assessment, at customer and at entity level;
- customer due diligence and enhanced due diligence, identifying the beneficial owner and the beneficial ownership register;
- suspicious transaction indicators and reporting to the FIU;
- restrictive measures and monitoring EU and UN sanctions lists;
- virtual assets and the latest requirements of the EU directives;
- the FIU's requirements and expectations during supervision.
The role of the authorised person
The authorised person and their deputy are responsible for applying AML/CFT measures within the entity: the risk assessment, internal procedures, customer due diligence, reporting suspicious transactions to the FIU and organising staff training. That is why the authorised person also needs to keep up with changes in regulation and practice.
What the FIU checks during supervision
The Financial Intelligence Unit and the other supervisory bodies designated by the Law check whether the entity applies the measures in practice, not only on paper. For training, this means:
- whether there is an annual training plan and whether it was carried out;
- whether at least two trainings were held during the year, and who attended;
- whether there is evidence: certificates of participation, attendance lists, the programme and materials;
- whether employees know the suspicious transaction indicators and the internal procedures.
Beyond training, supervision also covers the risk assessment, internal acts, customer due diligence and suspicious transaction reporting. Our training "Compliance with the AML/CFT Law – FIU Requirements and Expectations in Supervision" looks at how supervision works in practice.
How IARB can help
The Institute for Applied Research for Business runs certified online AML/CFT trainings with training materials, led by practitioners in the field. For financial companies and other entities we also organise trainings tailored to their business. Upcoming dates are in the Training Calendar; to register or ask a question, write to info@iarb.edu.mk or call +389 70 669 085. Trainings are held in Macedonian.
This page is a general overview of the obligations and is not legal advice. For specific questions, consult the Law on the Prevention of Money Laundering and Financing of Terrorism and the Financial Intelligence Unit.
Next AML/CFT training
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Frequently asked questions
Which entities must provide AML/CFT training?
The obliged entities defined in Article 5 of the Law on the Prevention of Money Laundering and Financing of Terrorism: financial institutions and their subsidiaries and branches, accountants, lawyers, notaries and other non-banking entities, and organisers of games of chance.
How many trainings a year does the law require?
At least two AML/CFT trainings a year for employees, under Article 12(1)(12) and Article 68(14) of the Law.
Who should attend the training?
Employees who work with customers and transactions, as well as the authorised person and their deputy, who are responsible for applying AML/CFT measures within the entity.
How do I prove that the training took place?
Keep the certificates of participation, attendance lists, programme and materials of each training, together with the annual training plan. These are the documents requested as evidence during supervision.
Is online training accepted?
The law requires the training to take place; it does not specify whether it is online or in person. What matters is that the training covers the obligations under the law and is documented with a certificate and materials.
Where can I find a training?
The Institute for Applied Research for Business runs certified online AML/CFT trainings. Dates are published in the Training Calendar; to register, write to info@iarb.edu.mk.