Advanced AML Training: Subjective Unusual Transaction Reporting | Practical Approach

From Unusual Activity to Defensible Reporting

The regulator increasingly focusses not only on whether Unusual Transaction Reports (UTRs) are submitted on time, but on how suspicion is identified, assessed, documented, and justified.

This advanced AML training is designed for experienced professionals who already understand AML fundamentals and now need to strengthen professional judgment, decision-making, and regulatory defensibility.

The course provides a practical, expert-level framework for assessing unusual activity, determining when suspicion arises, and deciding whether to escalate, monitor, or report, in line with:

  • the AML/CFT State Ordinance
  • the FIU Indicators
  • current supervisory expectations, including the FIU requirements of November 2023

This training moves beyond typologies and red flags and focuses on the quality of AML analysis and decision-making, one of the most frequent areas of regulatory criticism.

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What will be covered:

This training helps institutions demonstrate that UTR decisions are:

  • Risk-based
  • Well-reasoned
  • Consistently applied
  • Clearly documented
  • Defensible during inspections and reviews

Participants will learn how to:

  • Distinguish unusual activity from suspicious activity
  • Assess context, customer behavior, and economic rationale
  • Apply professional judgment in subjective UTR decision-making
  • Decide when monitoring is sufficient and when reporting is required
  • Document decisions in a manner the FIU and Supervisor expect to see
  • Avoid common supervisory findings related to subjective UTRs

Duration of the training

4 Hours

Time

8:30 AM – 12:30 PM

Date

30 September 2026

Price

Afl. 525 = p.p.

In-house Training

Please contact us to arrange your
in-house face-to-face training.

Online Registration

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