When must new employees of a CMA licensed firm complete AML training?
Within 30 days of joining. A CMA licensed entity must provide necessary and appropriate AML compliance programme training to all newly joined employees within 30 days from their date of joining, and must restrict newly joined employees from independently serving any client until they have successfully completed that training.
That second limb is the one with operational teeth: an untrained new joiner cannot be put in front of clients on their own. Before building the training plan, the firm must conduct a training needs analysis identifying requirements by role, responsibility and level of risk exposure for each employee. It must also have a comprehensive training policy covering the types of training required, the frequency, and the employees targeted, and must evaluate the programme’s effectiveness regularly and whenever federal AML legislation or the compliance programme changes.
Legal Reference (UAE CMA):
· CMA Rulebook Chapter Five, AML/CFT Controls, Chapter Nine Article 3(4) and (5): training within 30 days of joining and the restriction on independently serving clients.
· CMA Rulebook Chapter Five, AML/CFT Controls, Chapter Nine Articles 1 and 2: the training policy and the training needs analysis.
· Cabinet Resolution No. 134 of 2025, Article 21: ongoing employee training as part of internal controls.
This answer covers entities licensed by the UAE Capital Market Authority (CMA). Firms in ADGM or DIFC follow their own regulator’s rulebook and the requirements differ.