Training Objectives

At the Knowledge Level, participants will be able to:
• Describe the AML/CFT framework and key obligations of EMIs.
• List the stages and components of an effective AML compliance programme.
• Identify main ML/TF and fraud typologies relevant to EMIs.
• Clarify the relationship between AML, fraud risk, and governance structures.
• Correlate AML obligations with customer risk management and transaction monitoring processes.

At the Skills Level, participants will be able to:
• Develop and implement proportionate AML and fraud controls.
• Perform business-wide and customer risk assessments (BWRA and CRA).
• Explain and justify due diligence and monitoring decisions.
• Organise reporting procedures for suspicious transactions and internal escalation.
• Justify risk-based thinking to strengthen internal governance and operational frameworks.

At the Attitudes Level, participants will be able to:
• Challenge weak compliance practices and promote accountability.
• Motivate colleagues to maintain a culture of integrity and vigilance.
• Defend the importance of ethical conduct in financial services.
• Appraise and evaluate the effectiveness of internal AML and fraud processes.
• Promote continuous improvement and readiness for supervisory inspections.

Training Outline

AML/CFT Regulatory Framework for EMIs

• Cyprus AML Law and CBC Directive (2025 revision)
• The upcoming EU AML Regulation (EU) 2024/1624, Directive (EU) 2024/1640
• Overview of PSD2 and the Electronic Money Directive
• Supervisory roles: CBC, MOKAS, and FIU cooperation
• Risk-based approach and proportionality principle

Business-Wide and Individual Risk Assessments (BWRA & CRA)

• Purpose and regulatory requirement for the BWRA
• Key risk factors: products, geography, delivery channels, customers
• Methodology and documentation
• Link between BWRA and CDD measures
• Individual Customer Risk Assessment (CRA): scoring models and consistency with BWRA
• Periodic review and update of risk assessments

EMI-Specific ML/TF Risks and Red Flags

• ML/TF typologies common in EMIs
• Abuse of EMI accounts and e-money products
• Merchant and customer-related vulnerabilities
• Agent and distributor risks
• Indicators of suspicious activity

Fraud Risk Management

• Fraud obligations under PSD2 and EBA Guidelines
• Strong Customer Authentication (SCA) and exemptions
• Transaction monitoring and fraud detection
• Internal fraud prevention measures
• Incident reporting and collaboration between AML and fraud teams

Transaction Monitoring and Reporting Obligations

• Transaction monitoring frameworks and system alerts
• Suspicious Transaction Reports (STRs) to MOKAS
• Internal escalation and decision-making process
• Tipping-off prohibition
• Feedback and remediation processes

Governance, Culture, and Oversight

• AML governance and roles (Board, AMLCO, management)
• Policies, controls, and independent review
• Training and awareness
• Preparing for supervisory inspections

Who Should Attend

This programme is designed for professionals working within Electronic Money Institutions (EMIs) and Payment Institutions (PIs) who hold compliance, operational, or decision-making responsibilities, including:

• Board Members responsible for AML/CFT oversight
•  Compliance and Risk Officers
• AML Officers and Managers
• Transaction Monitoring and Fraud Prevention Officers
• Frontline and Operations Staff involved in customer onboarding and payments management

CPD Recognition

This programme may be approved for up to 6 CPD units in Banking and Financial Regulation. Eligibility criteria and CPD Units are verified directly by your association, regulator or other bodies which you hold membership.

This training course may be approved as an external activity under the new ACAMS recertification category ”non-ACAMS credits” for up to 5 CPD units. Eligibility criteria and CPD Units are verified directly by the Association of Anti-Money Laundering Specialists (ACAMS). To read more about the non-ACAMS credits policies and eligibility criteria please click here.

In-house Training

For groups within the same organisation, this course may be customized to meet any specific needs and delivered in-house.