AML training: preparing advisors for the due diligence interview

Effective AML training (in France, LCB-FT: anti-money laundering and counter-terrorist financing) prepares the advisor to conduct the due diligence interview out loud. They must ask the question about the source of funds, hold their ground when a customer gets irritated and never reveal a suspicion. The law requires staff to be trained, but the difficult moment is a conversation, not a course.

This article is based on the French Monetary and Financial Code and describes the interview step by step. The legal framework is French; readers elsewhere should compare it with the rules that apply to them. It gives the phrases to use and those to avoid. It ends with a checklist the trainer can reuse for debriefing.

What does the law say about AML training?

Article L. 561-34 of the French Monetary and Financial Code requires covered entities to inform their staff regularly. They must also set up suitable training programs. The supervisory authorities check that these obligations are met.

Training must therefore be regular and suited to the job. A branch advisor, a wealth manager and a back-office employee do not have the same situations to handle. The texts leave the format to the organization: what matters is that people know how to react.

The wider framework is that of due diligence and reporting obligations. It appears in the work of the ACPR and Tracfin, whose joint guidelines describe expectations for financial institutions. Read them on the ACPR and Tracfin websites before writing your scenarios.

The due diligence interview: what must the advisor obtain?

Under Article L. 561-10-2 of the French Monetary and Financial Code, enhanced scrutiny is required in three cases. The transaction is particularly complex, of an unusually high amount, or has no apparent economic justification or lawful purpose. The institution then asks the customer about the origin and destination of the funds, the purpose of the transaction and the identity of the beneficiary.

The advisor therefore conducts a real interview, with four objectives.

1. Understand the transaction. What is it, why now, why this amount?
2. Establish the origin of the funds. Salary, sale of a property, inheritance, savings: the customer explains and, if needed, provides supporting documents.
3. Identify the beneficiary. Who receives the funds, and what is their link to the customer?
4. Write it down. The answers and the outcome of the review are kept, in line with the institution's internal procedures.

If the answers do not dispel the doubt, what follows is the suspicious transaction report provided for in Article L. 561-15. This decision is taken with the compliance department. The advisor neither decides alone, nor discusses it with the customer.

What phrases should you say during the interview?

Tone matters as much as the question. A due diligence question presented as a general procedure is received far better than one that sounds like suspicion. Here are wordings to work on out loud.

To open the exchange:

“For a transaction of this amount, we need to understand where the funds come from. Could you explain?”

To ask for a supporting document:

“To finalize, I need a document that confirms this origin, such as the property sale documents.”

To follow up without accusing:

“I haven't quite understood the link with the recipient. Could you clarify?”

To close:

“Thank you, that's enough information for now. I'm passing the file on for processing.”

The wordings stay factual. They describe what the advisor needs, never what they think of the customer.

What to do when the customer gets irritated or refuses to answer?

This is the situation where e-learning is of no use. The customer says they have been a customer for ten years, that these questions are insulting, that they will switch banks. The advisor feels the commercial relationship weakening and the temptation to give in arrives quickly.

Three reflexes help.

• Acknowledge without giving in. “I understand this is unpleasant.”
• Recall the common framework. “These questions apply to all our customers for this type of transaction.”
• State the consequence without threatening. “Without this information, I can't process the transaction today.”

The advisor does not justify at length. They do not apologize for applying the rule. The pressure mechanisms are the same as in the phone scam: urgency, authority, guilt. Our article on saying no on the phone under pressure details phrases that transfer across.

How to avoid revealing a suspicion (tipping-off)?

Asking due diligence questions is not revealing a suspicion. What is forbidden is to disclose to the customer or to third parties that a report has been made or is under review. Article L. 561-18 of the French Monetary and Financial Code makes the suspicious transaction report confidential. It prohibits disclosing it, under the penalties provided for in Article L. 574-1.

In practice, the advisor never says any of these three phrases.

• “We have reported your file.”
• “Your transaction is suspicious.”
• “Tracfin may contact you.”

They can say:

“We can't process this transaction as it stands. Let me tell you what we're missing.”

Beginners often fail on both sides. Either they stay silent for fear of saying too much, or they explain too much to calm the customer. Training consists of finding the right sentence, neither evasive nor revealing.

Why e-learning is not enough for due diligence

A module can explain the legal framework and the warning signs. It does not make you feel the pressure of a customer raising their voice. Yet that is where vigilance is lost: so as not to upset anyone, the advisor does not dare ask the second question.

Spoken practice acts on three points. It makes you formulate the question, it exposes you to the tension of the relationship, and it lets you play again after precise feedback. The same finding applies to all obligations, as our page on mandatory compliance training through practice scenarios describes. The article on completion versus competence explains why a quiz pass rate does not prove this ability.

Training the due diligence interview through role play

A due diligence interview role play puts the advisor in front of a persona played by an AI. This customer wants to send a large wire transfer and tolerates questions badly. The trainer sets the profile, the amount, the degree of insistence and what the advisor must obtain.

Imagine a customer who wants to move a large sum to an account abroad, and who first answers with “it's my money”. The advisor must ask the origin question, rephrase, request a supporting document and close without revealing anything. The session lasts a few minutes.

With Face Up, trainers create these scenarios from their own cases, with a design assistant. The learner speaks, by voice or on video. The debrief gives objectives met or not, strengths, points to improve, an action plan and quotes. They can play again. For banking in general, see the article on awareness training in banking.

Advisors' common mistakes

Debriefs of this type of interview bring out the same gaps.

• Apologizing for asking the question. “Sorry, it's the procedure” weakens the request. Better: “it's a question we ask everyone”.
• Accepting a vague answer. “It's family money” establishes nothing. The advisor follows up: “What kind, and over what period?”
• Asking all the questions at once. The customer feels interrogated. One question at a time, then listening.
• Improvising a legal explanation. A poor quotation of an article of law exposes the advisor. They refer to compliance.
• Forgetting to record. An interview that is not noted does not exist for the auditor.

These mistakes are corrected through repeated practice. A first session reveals the gap, the second shows progress.

Debrief checklist for the trainer

This checklist can be reused for each session.

• Did they ask the question about the source of funds in the first few minutes?
• Did they ask for the beneficiary's identity and the link with the customer?
• Did they present the question as a procedure applying to everyone?
• Did they hold firm in the face of irritation without justifying at length?
• Did they avoid any allusion to a report or a suspicion?
• Did they say clearly what is missing to process the transaction?
• Did they mention written recording and referral to compliance?

Keep the debriefs: they complement attendance certificates. The article on proof of training and the audit trail details what an auditor expects.

Frequently asked questions

Is AML training mandatory for all employees?

Article L. 561-34 applies to covered entities, which must train their staff in a suitable way. The priority groups are those in contact with customers and those who process transactions. Your compliance officer sets the scope according to the risk mapping.

Can an advisor tell the customer that the question is mandatory?

Yes, and it is even recommended. Presenting the question as a legal obligation common to all customers depersonalizes the exchange. What they must not say is that a report has been made or that a suspicion exists.

What if the customer refuses to answer?

The advisor explains that they cannot process the transaction without the information requested, then alerts compliance. What follows, including any suspicious transaction report, is a matter for the compliance department and not for the advisor alone.

To test a due diligence interview on one of your real cases, book a demo and build the scenario with us. Related obligations are covered in anti-corruption training under the French Sapin II law.