AML Course for EMIs: AML Foundations for E-Money Institutions

• Financial crime and predicate offences: how proceeds are placed, layered and integrated, and which of those stages a payments book actually sees.
• Risk and its management: business-wide risk assessment, customer risk models, product risk, and the delivery-channel risk that remote onboarding creates.
• Compliance programme components: CDD, EDD, ongoing monitoring, sanctions and PEP screening, record-keeping, and reporting to the FIU.
• When to restrict, exit or refuse a customer relationship, and how to document that decision so it survives review.
• Regulators, rules and the cost of getting it wrong: who supervises an EMI, what they inspect, and what published enforcement has actually punished.
• Codes of ethics and codes of conduct, and why the difference matters when a commercial target and a control decision point in opposite directions.

Safeguarding of customer funds sits next to AML, not inside it

A bank takes deposits. An electronic money institution issues e-money against funds it receives, and those funds are safeguarded rather than deposited: segregated in a safeguarding account, or covered by an insurance policy or comparable guarantee, under the model set out in Article 10 of PSD2 and applied to e-money issuers through the Electronic Money Directive. Under the segregation route, relevant funds must not be commingled with the institution’s own money and must be placed in a separate account by the end of the business day following receipt.

Safeguarding is a prudential obligation. It is not an AML obligation, and this is not a safeguarding reconciliation course. But the two meet daily, and the course treats that meeting point directly: an unexplained break between the safeguarding account and the customer ledger is a control failure and a financial crime signal at the same time, and the person who spots it is usually in operations rather than in compliance.

Agents and distributors are your risk, not theirs

EMIs reach customers through agents and distributors who sit outside the institution’s own payroll. The Bank of Lithuania put it plainly in June 2023: the activities of selected agents and e-money distributors are the responsibility of the financial institutions. So screening before appointment, contractual liability, training the network and monitoring what it does afterwards are treated here as first-line AML work rather than as procurement.

That is also where the money has gone. The Bank of Lithuania fined Revolut Bank UAB €3.5 million in April 2025 over AML control failures, and control failures at scale in a payments business are rarely one bad decision. They are a monitoring rule that never fired, repeated a few hundred thousand times.

Passporting means home-state authorisation, not home-state-only scrutiny

Passporting lets an EMI authorised in one Member State serve customers across the EEA. Where it operates through agents or distributors instead of branches, a host Member State may require a central contact point to handle AML compliance and to answer supervisory requests, a power carried in Directive (EU) 2024/1640. The course covers what that means for reporting lines and for who actually holds the file.

Material is written by practitioners and delivered as reading, animated video and diagrams. And the diagrams earn their place here: a payment flowing through an issuer, a distributor, a scheme and an acquiring bank is far easier to reason about drawn than described.

One honest limit. This is a foundations programme. If you already own an EMI’s transaction monitoring rule set or hold an MLRO appointment, start at CASS instead — you’ll find this level thin, and we’d rather say so now than after you have paid.

AML Foundations for EMIs is delivered by the AML Certification Centre and is built around the AML/CTF obligations an electronic money institution carries: remote customer onboarding, e-money issuance and redemption, agent and distributor oversight, sanctions and PEP screening, transaction monitoring across a high-volume low-value book, and reporting to the FIU. It sits inside the payment services framework rather than treating that framework as background, so PSD2 and the Electronic Money Directive appear where they belong instead of in a footnote.

• Learning method: online, self-paced.
• Duration of course materials: 12 hours.
• Duration of video materials: 4 hours.
• Submodules: 23, across 7 modules.
• Assignments: 30.
• Visual schemes: 26.
• Format: video, textual materials, diagrams.
• Practical materials: yes.
• Interactive quizzes: yes.
• Final exam: 30 questions.
• Duration of final exam: 60-minute time frame.
• Exam passing threshold: 80%
• CPD credits: 12.
• Recommended learning timeline: 2 weeks.
• Access: lifetime.

Two weeks is a recommended pace, not a deadline. Most people studying alongside a full-time compliance role take three to four, and access doesn’t expire. So there’s no penalty for slowing down across a quarter-end.

Work through the modules, pass the final exam at 80% or above, and the AML Certification Centre issues a Certificate of Completion carrying 12 CPD credits. It records that you covered the AML/CTF+ material and passed an assessment rather than attended a session.

But be precise about what that certificate is, because vagueness here costs people interviews. It evidences the competence of a person. It is not a licence, and it is not an endorsement, approval, accreditation or recognition by any regulator — not the FCA, not BaFin, not the Bank of Lithuania, not the Central Bank of Ireland, not the MFSA, and not the EBA or AMLA. No training provider anywhere can grant that, and you should treat any that claims to with suspicion.

What it does do is answer the staff-training question a supervisor asks during an inspection, with a dated record tied to an assessment. For an individual, it makes an entry-level financial crime application readable. For an EMI, it is training evidence. Both uses are legitimate. Neither is a substitute for the firm’s own authorisation.