AML Certification Centre – Core Code of Conduct

Preamble

AML Certification Centre (“the Centre”) is committed to the highest standards of ethics, integrity, and professionalism in all its activities. This Core Code of Conduct (“the Code”) sets out the principles and expectations for ethical behavior and operational conduct that all individuals associated with the Centre must follow. Our mission of providing excellence in Anti-Money Laundering (AML) education and certification globally is underpinned by a culture of honesty, respect, and accountability. By adhering to this Code, we ensure that our work not only complies with laws and regulations but also upholds the trust placed in us by the public and the financial crime compliance community. This Code is a public document and applies worldwide, reflecting global best practices and global English standards in its language and intent.

Scope and Applicability

This Code of Conduct applies to all persons involved with AML Certification Centre, regardless of location. This includes, but is not limited to:

Employees and Staff: All full-time, part-time, and temporary staff, including management.
Partners and Contractors: External partners, consultants, contractors, and service providers acting on behalf of or in collaboration with the Centre.
Advisory Board Members: Individuals serving on the Centre’s boards or committees.
Experts and Instructors: Trainers, speakers, subject matter experts, and facilitators engaged in the Centre’s programs.
Learners and Trainees: Individuals enrolled in training, certification courses, or any educational programs provided by the Centre.
Members (Present and Future): Any members of the Centre’s professional community or alumni network, including future members as such programs are established.

Each individual in the above categories is expected to understand and comply with this Code. Compliance with the Code is a condition of participation in the Centre’s activities and, for staff and contractors, a condition of employment or engagement. Where local laws or regulations impose stricter standards than those set out in this Code, those stricter standards must be followed. Conversely, if the Code sets higher standards than local requirements, the standards of this Code should be met. In all cases, when in doubt about the proper course of action, individuals are encouraged to seek guidance from a supervisor, the Centre’s management, or the Ethics Committee (described below).

Ethics and Integrity

All persons bound by this Code must conduct themselves with unwavering ethics and integrity. This means:

Honesty and Fair Dealing: Always be truthful and forthright in all professional activities. Do not engage in fraud, deceit, or misrepresentation. We expect everyone to act in good faith and to deal fairly with colleagues, learners, and stakeholders. Misconduct such as cheating (for example, in exams or assessments) or facilitating dishonesty by others is strictly prohibited.
Compliance with Laws and Regulations: Abide by all applicable laws and regulations in every jurisdiction where we operate, especially those related to financial crime prevention. This includes full compliance with Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and sanctions laws, as well as any other relevant regulations in areas such as data protection, employment, and safety. We uphold internationally endorsed standards, recognizing that the FATF Recommendations are the global benchmark against money laundering and terrorist financing . All staff, partners, and learners are expected to be vigilant and proactive in following these laws and standards in their roles.
Integrity in Professional Duties: Perform your duties responsibly and diligently. Ensure accuracy in all work (for instance, in training content, assessments, record-keeping, or communications). Intellectual honesty is paramount: credit sources of information appropriately and do not plagiarize or infringe on intellectual property. If you discover errors or wrongdoing, promptly disclose and correct them rather than concealing them.
Objectivity and Impartiality: Decisions (such as grading of learners, partnership deals, or any other professional judgments) should be made based on merit and facts, free from bias or undue influence. Personal relationships or outside pressures must not compromise your professional objectivity.

By embracing these principles of ethics and integrity, we ensure that the Centre’s reputation for trustworthiness and excellence is maintained. Each individual should ask themselves whether their actions align with both the letter and spirit of this Code and the Centre’s values. If an action would embarrass the individual or the Centre if made public, it should be reconsidered. Acting with integrity builds the foundation for all other expectations in this Code.

Professional Behavior

Professionalism is expected in all interactions and duties associated with the Centre. This means maintaining the highest standards of conduct, competence, and accountability:

Quality and Diligence: Carry out your responsibilities to the best of your ability and with appropriate care. Prepare thoroughly for training sessions, meetings, or tasks. For instructors and experts, ensure content delivered is accurate, up-to-date, and aligns with the Centre’s learning objectives. For staff and contractors, execute tasks efficiently while adhering to established procedures and quality standards.
Accountability: Take responsibility for your actions and decisions. Meet deadlines and commitments, or communicate proactively if challenges arise. Acknowledge and learn from mistakes rather than deflecting blame. Each person is accountable for upholding the Centre’s mission and the commitments made to colleagues, learners, and partners.
Professional Courtesy: Treat all individuals with whom you interact in a business context with respect and courtesy. This includes being punctual for meetings or training sessions, listening actively to others, and communicating in a constructive and collegial manner. Even in challenging situations or discussions, maintain a calm, respectful tone. Use of profanity, aggressive behavior, or any form of rude conduct is not acceptable in our professional environment.
Appropriate Use of Communication Channels: Use official and approved communication channels (such as company email, learning platforms, or other designated systems) for conducting Centre-related business. This helps maintain security and confidentiality. Avoid discussing sensitive Centre matters on unofficial platforms or social media. Professional behavior extends to digital communications: emails, messages, and online posts related to the Centre should be composed with the same level of professionalism as face-to-face interactions.
Health and Safety: Adhere to all health and safety guidelines when participating in any on-site training, events, or office activities. Report any hazardous conditions or incidents promptly. A professional takes care not only of the quality of work but also ensures the environment is safe for everyone.

By upholding professional behavior, we create a productive, reliable, and positive environment that enables the Centre’s educational mission to thrive.

Respect and Non-Discrimination

We are committed to a diverse, inclusive, and respectful environment free from discrimination, harassment, or bullying. Every individual has the right to be treated with dignity. To this end:

Equal Opportunity and Fair Treatment: The Centre strictly prohibits discrimination in any form. It is forbidden to discriminate or treat anyone disrespectfully on the grounds of race, ethnic origin, nationality, religion, opinions or beliefs, gender, sexual orientation, health status, disability, or any other characteristic protected by law . Decisions regarding hiring, promotion, admission to programs, or any opportunity must be based on merit and qualifications, never on personal traits unrelated to performance.
Harassment-Free Workplace and Learning Space: Harassment of any kind – whether verbal, physical, sexual, or psychological – is strictly prohibited . This includes offensive comments, unwanted physical contact, inappropriate jokes or visuals, or any behavior that could reasonably be perceived as demeaning, hostile, or intimidating. All individuals should avoid conduct that might humiliate or offend others or create an inhospitable environment . Sexual harassment (such as unwelcome advances or suggestive remarks) and bullying (repeated mistreatment that harms or intimidates) will not be tolerated.
Culture of Respect: We operate across different cultures and value each individual’s background. Cultural differences are never an excuse for disrespectful behavior. Everyone is expected to be sensitive to cultural norms and practice courtesy, dignity, and respect in all interactions . Instructors and staff should foster an inclusive atmosphere in classrooms (physical or virtual) and meetings, where all participants feel comfortable contributing.
Safe and Inclusive Environment: If you witness or experience any form of discrimination, harassment, or disrespect, you are encouraged to speak up or report it (per the Reporting procedures in this Code). The Centre will take such reports seriously and handle them with confidentiality and care. Retaliation against anyone who in good faith reports disrespectful or discriminatory behavior is strictly forbidden (see Enforcement section). Our aim is to create an environment where everyone – employees, partners, and learners alike – feels safe, valued, and able to fully engage in our programs and activities.

By embracing diversity and insisting on mutual respect, we strengthen the integrity and effectiveness of our training and collaboration. Every individual’s contribution is important, and maintaining respect and fairness is fundamental to our collective success.

Confidentiality and Data Protection

Throughout our work, we often handle sensitive information. Maintaining confidentiality is both an ethical obligation and, frequently, a legal requirement:

Confidential Information: Any non-public information learned or developed through the Centre’s activities must be protected. This includes, for example, business strategies, financial information, training materials not released publicly, examination content, personal data of learners or employees, client or partner information, and any other information designated as confidential. Such information should not be disclosed or made publicly available without proper authorization . Even within the Centre, share confidential information strictly on a need-to-know basis.
Privacy and Personal Data: Respect the privacy of individuals. Personal data (such as contact details, identification information, or assessment results of learners) should be collected, used, and stored in compliance with data protection laws and the Centre’s policies. Only use personal information for legitimate Centre purposes and protect it from unauthorized access. If you handle personal data, ensure you follow any applicable regulations (for example, GDPR for EU data subjects or other local privacy laws) and the Centre’s data protection guidelines.
Secure Communication: Use approved secure channels for transmitting confidential or sensitive information. Avoid using personal email or unsecured messaging services for work-related confidential communications, as these may not provide adequate security . If working across time zones or remotely, be mindful of security (for instance, using VPNs or encrypted services as provided by the Centre). Also, respect reasonable working hours and boundaries when communicating; unless urgent, avoid expecting immediate responses outside of normal working hours .
Intellectual Property and Materials: Materials created by or for the Centre (such as curricula, presentations, documentation, software, and research) are the Centre’s intellectual property (IP) unless otherwise agreed. Treat these assets as confidential unless they are published or approved for public release. Do not share, reproduce, or use the Centre’s training content, certification exam questions, trademarks, or logos outside authorized activities. Even after your association with the Centre ends, the obligation to maintain confidentiality of the Centre’s proprietary information continues.
Exceptions and Required Disclosures: If you believe there is a legal obligation to disclose certain information (for example, a court order or a regulatory requirement such as a duty to report a suspicious activity in line with AML laws), you should promptly inform the appropriate Centre authority (e.g., management or legal counsel) and follow their guidance. Do not independently release information without authorization. In any case, any disclosure of confidential information must be strictly limited to what is required or permitted by law.

By safeguarding confidentiality and data privacy, we protect the trust that others place in the Centre and ensure compliance with laws. Breaches of confidentiality can severely damage the Centre’s reputation and effectiveness, and thus are taken very seriously.

Conflicts of Interest

All personnel and associates of the Centre must act in the best interests of AML Certification Centre and avoid situations where personal interests conflict, or appear to conflict, with those of the Centre or its mission. Key guidelines include:

Avoidance of Conflicts: You should avoid any actual, potential, or apparent conflict of interest in relation to your work . A conflict of interest arises when personal, financial, or other outside interests could influence or be perceived to influence your decisions or actions on behalf of the Centre. This may include situations where you or a family member have a stake in an entity that does business with the Centre, or if you are engaged in outside employment/activities that could compromise your objectivity.
Disclosure: If a potential conflict of interest arises, you must disclose it promptly to the Centre’s management or the Ethics Committee. Transparency is essential. Examples of scenarios requiring disclosure include: a staff member having a second job with a competitor or supplier; an instructor who is asked to promote materials from a company in which they have a financial interest; a board member who has a personal relationship with a candidate being considered for a role or award. Early disclosure allows the Centre to evaluate the situation and decide on next steps (such as recusal from decision-making, or obtaining approvals with conditions).
Gifts and Hospitality: As part of avoiding conflicts and corruption (see also Anti-Corruption section), exercise caution in offering or accepting business gifts, hospitality, or favors. Small tokens of appreciation can be part of normal business courtesy, but anything of more than nominal value could create a perceived obligation or bias. Accepting gifts, entertainment, or other benefits that could influence, or appear to influence, your objectivity or decision-making is not allowed. If in doubt about the propriety of a gift or invitation, seek advice from the Ethics Committee or management. In general, any gift or hospitality that is lavish or beyond common courtesy should be politely declined or requires explicit approval.
Impartiality in Decision-Making: Those in leadership or advisory roles must take particular care to remain impartial . For instance, if you are in a position to influence hiring, contracting, or learner admissions, do not let personal relationships or external pressure sway your decisions. Make decisions based on merit and factual criteria. If you find you cannot be impartial (e.g., the candidate is a close friend or relative), recuse yourself from that process.
Outside Engagements: Employees and closely affiliated persons should seek permission as required by Centre policy before taking on any outside employment, directorship, or significant volunteer role, especially if it may relate to AML or compliance fields. The Centre may prohibit outside activities that conflict with its interests or the availability and focus of its staff. Likewise, using Centre resources or time to advance personal business or political interests is not permitted.

By proactively managing conflicts of interest, we uphold the integrity of the Centre’s operations and ensure that trust—both internally and with our stakeholders—is maintained. Remember that even the appearance of a conflict can be damaging; when in doubt, disclose and consult.

Anti-Corruption and Anti-Bribery

AML Certification Centre has zero tolerance for corruption, bribery, or any form of unethical business practice. As an organization rooted in the fight against financial crime, we hold ourselves to the highest standards of integrity in all dealings:

Prohibition of Bribery: Offering, giving, soliciting, or receiving any form of bribe is strictly forbidden. No one acting on behalf of the Centre may, directly or indirectly, promise, give or accept anything of value to improperly influence a decision or gain an unfair advantage. This applies to interactions with government officials, private companies, and individuals alike. All employees, partners, and vendors must comply with anti-bribery laws such as the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any local anti-corruption laws, as applicable . We also uphold anti-money laundering laws and regulations in spirit and practice, aligning with global efforts to combat financial crime .
Gifts and Entertainment: Business gifts, hospitality, or charitable donations on behalf of the Centre must never be used as a subterfuge for bribery. While fostering good relationships is important, any gift or hospitality must be modest, infrequent, and cannot be intended to influence a business outcome. As noted under Conflicts of Interest, offering or accepting excessive or lavish meals, travel, or entertainment is prohibited. When in doubt, seek approval from management or the Ethics Committee before proceeding. A good rule of thumb is to ask: Would I be comfortable if this exchange was made public? If not, avoid it.
Facilitation Payments: So-called “facilitation” or “grease” payments (small unofficial payments to expedite routine government actions) are treated as bribes under this Code and are not permitted, even if they might be common practice in some jurisdictions. If you are asked to make any improper payment, refuse and report the incident to the Ethics Committee or senior management immediately.
Political and Charitable Contributions: Any political contribution or charitable donation made on behalf of the Centre must be approved by senior management and must comply with law. The Centre itself is generally apolitical and does not contribute to political campaigns. Individuals are, of course, free to participate in political activity in their personal capacity, but must not use the Centre’s name, funds, or resources to do so (see also Use of Name and IP section).
Training and Awareness: The Centre will provide training and resources to help staff and associates understand and comply with anti-corruption laws and this Code. All relevant persons are expected to complete any mandatory anti-corruption or AML training and stay updated on policies. Vigilance is key—if you suspect any corrupt activity related to the Centre’s operations or by any colleague/partner, you are required to report it (confidentially, if needed) to the Ethics Committee (see Reporting and Enforcement). Remember that corruption and money laundering are intrinsically linked problems; by refusing to engage in bribery and reporting suspicious financial activities, we support broader efforts to combat corruption globally .

In summary, our stance is clear: integrity over profits or convenience, every time. No business opportunity or relationship is worth engaging in unethical conduct. Even a single act of corruption can severely damage our credibility and violate the law. By adhering strictly to anti-corruption principles, we maintain the trust of regulators, learners, and the public, and we set an example consistent with the standards we teach.

Use of Company Name, Assets, and Intellectual Property

As a professional organization, AML Certification Centre’s name, reputation, and intellectual property are valuable assets. All associated individuals must use these assets responsibly and protect them from misuse:

Use of Name and Logo: The Centre’s name, logo, and branding should be used only for official business and with proper authorization. You may not use the Centre’s name or logo in any publicity, advertising, personal business venture, or on websites without prior written approval from the Centre’s management . This includes implying endorsement by the Centre in external activities or using our name in public statements without permission. For example, if you are speaking at an event or writing an article in your personal capacity, do not suggest you are representing the Centre unless you have authorization to do so.
Representation and Endorsements: Only authorized individuals may speak on behalf of the Centre or make commitments for the organization. Unless your job role explicitly permits it, do not present yourself as an official spokesperson. Inquiries from media or public bodies should be referred to the appropriate Centre representatives. Similarly, do not use the Centre’s letterhead, email, or other assets to conduct personal business. Any endorsements or testimonials by the Centre must go through formal approval channels.
Intellectual Property (IP) Protection: The Centre’s courses, certification materials, research reports, logos, and other creations are protected by intellectual property laws (copyrights, trademarks, etc.). All staff, instructors, and learners must respect these rights. Do not copy, distribute, or modify Centre materials without permission. For learners, this means you should not share exam content or study materials in a way that violates the exam rules or this Code. For instructors and staff, any content you develop as part of your role (curriculum, slides, question banks, software code, etc.) typically belongs to the Centre unless otherwise agreed, and must remain with the Centre if you depart. Conversely, respect the IP of others – do not bring or use pirated software, plagiarized content, or unauthorized third-party materials in Centre activities.
Use of Resources and Facilities: Treat the Centre’s physical and digital assets with care. This includes equipment, facilities, IT systems, and funds. Use them only for legitimate Centre-related purposes. Incidental personal use of certain resources (like occasional personal phone calls or internet use) may be tolerated, but abusing this privilege (for instance, running a side business using Centre resources) is not allowed. All usage of Centre IT systems is subject to monitoring to ensure compliance with policies and security.
Social Media and Public Communications: When using social media or other public forums, do not reveal confidential information or speak as a representative of the Centre unless authorized. If you identify yourself as affiliated with the Centre (for example, in a LinkedIn profile or a personal blog), ensure that any opinions you express are clearly your own and not the Centre’s. Refrain from posting any content that could harm the Centre’s reputation or violate any aspect of this Code (such as disrespectful comments or confidential leaks).

By carefully controlling the use of our name and assets, we protect the integrity and credibility of the AML Certification Centre. Misuse of these assets not only undermines our brand but can also have legal consequences. Always when in doubt, seek guidance from management before using the Centre’s name or materials in any new or public context.

Reporting Concerns and Whistleblowing

Maintaining an ethical environment is a shared responsibility. If you see something, say something. All individuals covered by this Code are encouraged – and in some cases obligated – to report any suspected violations of this Code, unlawful activity, or other misconduct. The Centre is committed to ensuring that such reports can be made safely and without fear of retaliation:

Open Door and Advice: If you are unsure whether something is a violation or how to handle an ethical dilemma, you are encouraged to seek advice. This could be from your supervisor, a trusted manager, or directly from the Ethics Committee. The Centre fosters an open-door culture for ethical discussions. Often, issues can be resolved informally through honest communication. Minor interpersonal issues or misunderstandings, for example, might be addressed by speaking directly and respectfully with the person involved – as a first step – if you are comfortable doing so .
How to Report: For more serious matters or if direct resolution is not feasible, reports should be made to the Ethics Committee or designated channels (such as a confidential hotline or a specific email address, if provided by the Centre). The Centre’s Ethics Committee can be reached at [Insert Contact Method – e.g., a confidential email/portal]. Reports can be made in writing or verbally, and you may choose to report anonymously if local law permits and you prefer. Provide as much detail as possible to facilitate investigation (who, what, when, where, any evidence, etc.).
Protection of Whistleblowers: Retaliation against anyone who in good faith reports a concern or cooperates with an investigation is strictly prohibited . Retaliation includes firing, demotion, harassment, or any form of adverse treatment as a result of the report. Any person, regardless of rank, who retaliates against a reporter will face disciplinary action. We take reports seriously; even if a concern is not substantiated, as long as it was raised in good faith (meaning the reporter truly believed it to be true), the reporter is protected. On the other hand, malicious or knowingly false reports are themselves a violation of this Code.
Confidentiality in Reporting: The Centre will handle all reports with appropriate confidentiality. The identity of reporters and witnesses will be kept confidential to the fullest extent possible, consistent with the need to investigate and resolve the issue. Due regard will be given to confidentiality and the privacy of all parties involved, alongside considerations of due process . This means investigations will be conducted impartially and fairly, giving the alleged wrongdoer an opportunity to respond to allegations, while safeguarding sensitive information.

By reporting problems promptly, you give the Centre the opportunity to address issues before they escalate. Remember that unethical or illegal behavior can harm not just one person but the entire organization and its mission. Speaking up is an act of loyalty to the Centre’s values and to your colleagues. The Ethics Committee and leadership are committed to providing a safe avenue for this crucial aspect of our ethical culture.

Enforcement and Accountability

Adherence to this Code of Conduct is mandatory. Violations of the Code are taken seriously and may result in disciplinary action, up to and including termination of employment or affiliation, and if warranted, legal proceedings. The Centre has established structures and processes to enforce the Code impartially:

Ethics Committee Oversight: The Centre’s Ethics Committee is responsible for overseeing the implementation of the Code and addressing any breaches. This Committee consists of one Management Board member and an independent internal auditor (who is not involved in day-to-day management), ensuring a balance of leadership authority and independent oversight. The Ethics Committee’s duties include receiving reports of violations, leading or commissioning investigations, and recommending appropriate actions. It operates under principles of neutrality, confidentiality, and fairness.
Investigation Process: When a report of a possible Code violation is received, the Ethics Committee will review it promptly. If the matter falls within the scope of this Code, they will either investigate directly or appoint a qualified person or team to investigate. Investigations will be conducted objectively and discreetly. All individuals involved are expected to cooperate fully and honestly with investigators. The subject of the investigation will be given an opportunity to explain their perspective. The timeline for investigations will vary by case complexity, but matters considered severe (e.g., harassment, fraud, legal violations) will be prioritized.
Outcome and Disciplinary Actions: After the investigation, if a violation is substantiated, the Ethics Committee will determine or recommend appropriate corrective and disciplinary actions. These actions are case-specific and can include: a formal warning or reprimand; mandatory training or counseling; reassignment of duties; suspension of involvement in certain activities; or termination of employment/contract/association with the Centre. In cases of serious misconduct (for example, ethical breaches that threaten the integrity of the Centre’s programs, or illegal activities), the individual’s involvement with the Centre may be suspended or terminated . For instance, an instructor who is found to be cheating or a staff member engaging in harassment could be removed from their role.
Additional Enforcement Measures: Depending on circumstances, the Centre may also take further steps. The alleged offender may be asked to cease the offending behavior immediately (e.g., stop a conflict-of-interest activity or halt harassment). The Centre might also report the violation to appropriate external authorities . For example, if laws may have been broken (such as embezzlement, bribery, or abuse), or if the individual is subject to professional licensing, we may notify law enforcement or regulatory bodies. Where appropriate and necessary, serious matters (especially criminal in nature) will be reported to the police or relevant authorities .
Fairness and Due Process: Throughout enforcement, the Centre is committed to fairness. Evidence will be evaluated impartially. The accused individual will have the right to respond to findings before final decisions are made. We also recognize the importance of proportionality – disciplinary measures will correspond to the severity and nature of the violation, the impact on others, and whether it was a repeat offense or willful misconduct.
Transparency and Record-Keeping: The Ethics Committee will document all reported breaches and the outcomes of investigations. Summary reports (with sensitive details anonymized) may be provided to the Management Board to ensure accountability and to identify any trends that need addressing (such as recurring issues that might indicate a need for better training or policy changes). However, the privacy of individuals will be preserved in any public or broad communications. In some cases, the Centre may choose to communicate the outcome of a high-profile incident to stakeholders to demonstrate our commitment to enforcement (for example, letting members know that a person was removed for unethical behavior), but this will be done carefully and lawfully.

All members of the Centre community should recognize that enforcing the Code is essential to maintaining our credibility and ethical standard. No one is exempt from these rules due to position or contribution. Threats or acts of retaliation against those who report or enforce the Code are violations in themselves and will not be tolerated . Ultimately, our enforcement of the Code reflects our core belief that ethics and integrity are the foundation of our success.

Conclusion

This Core Code of Conduct embodies the values and principles that make AML Certification Centre a respected institution in the global fight against financial crime. Every stakeholder – whether a staff member, partner, instructor, learner, or board member – plays a part in upholding these standards. By following this Code, you are contributing to a culture of trust, excellence, and integrity that benefits everyone.

Please keep this document for reference and review it periodically. The Code may be updated from time to time to address emerging challenges or incorporate new regulations and best practices. The latest version will be made publicly available and communicated through official channels. It is each person’s responsibility to stay informed of and compliant with the current Code.

Thank you for your commitment to ethical conduct. Together, we ensure that the AML Certification Centre continues to operate with the highest ethical standards, setting an example for the community we serve and aligning with the broader international standards of ethics in AML and compliance. By living these principles, we not only avoid wrongdoing but actively create a positive impact in our field – fostering credibility, mutual respect, and a safer financial system for all.