Training and QA are where good AML frameworks quietly fail. A polished annual e-learning module with a 99 percent completion rate tells a board nothing about whether onboarding analysts actually recognise a structuring pattern or escalate the right way. Likewise, a quality assurance function that samples a handful of files each month, scores them green and never reaches the work of internal audit can give false comfort rather than genuine assurance. An AML training and QA review tests both: whether your training reaches the people who carry the risk and changes what they do, and whether your QA framework is designed and operating well enough to be relied upon.
Alsina Advisory delivers this as a focused, senior-led boutique. We are independent of any e-learning vendor, training provider or managed-service firm, so we have no module to sell you and no incentive to validate our own product. We work across the EU, rooted in the Netherlands, and we frame every finding against the obligations that supervise you, from the Wwft and DNB expectations to AMLD6, the AMLR and the EBA Guidelines. The result is a financial crime QA review your board and your national competent authority can take seriously.
What an AML training and QA review covers
We examine two connected questions, whether training works and whether your assurance over it works, across six areas scoped to your business model and risk profile.
Role and risk tailoring
Whether training is differentiated by role and risk exposure, so that front-line onboarding staff, transaction monitoring analysts, the MLRO and the board each receive content matched to the decisions they actually make.
Currency of obligations
Whether course content reflects current and incoming obligations, including the AMLR, AMLD6, EBA Guidelines and Dutch specifics such as reporting unusual transactions to FIU-Nederland rather than the suspicious-transaction language used elsewhere.
Completion and escalation
How completion, pass rates, refresher cycles and overdue training are tracked and escalated, and whether non-completion has real consequences rather than rolling over quietly each year.
Behavioural effectiveness
Whether training measurably changes behaviour, tested by linking it to quality of CDD files, alert handling and the volume and quality of internal escalations, not just by attendance and quiz scores.
QA framework and sampling
Whether the quality assurance framework over first and second-line activity is methodologically sound: risk-based sample selection, sample sizes, scoring criteria, calibration between reviewers and meaningful feedback loops.
Assurance over the lines
Whether QA and internal audit coverage of the financial crime framework is independent, IIA-aligned and free of conflicts, and whether second and third-line findings are tracked through to genuine closure.
How the review works
Scoping
We start with a short scoping conversation about your population, training model, QA arrangements and objectives, then agree the scope, timeline and a fixed fee or day rate in writing up front.
Evidence and testing
We review training materials, completion data, QA methodology and sampled QA workpapers, interview the first, second and third lines, and test a sample of real cases rather than relying on self-assessment.
Effectiveness assessment
We assess training against role and risk, currency and behavioural impact, and assess the QA framework against good practice and IIA standards, rating design and operating effectiveness for each.
Reporting
You receive a clear, prioritised report any board member or supervisor can follow: findings, root causes, risk ratings and pragmatic recommendations for both training and QA.
Independent re-testing
Where you need it, we re-test remediated training content or QA processes and provide independent confirmation that the gaps have been closed.
What you get
Why an independent review
Independence is the point, and it is especially pointed here. Asking the team that built the training, or the QA function under review, to assess its own effectiveness rarely surfaces the hard truths. We do not sell e-learning, we do not provide your managed QA, and we have nothing to validate, so our findings carry weight with your board and your national competent authority.
As a senior-led boutique, your engagement is run by an experienced financial crime auditor who has built and tested these controls in practice, holding the CIA, CAMS and ICA among other accreditations, not handed to a bench of juniors. That means sharper findings, fewer people in your environment and a report you can stand behind. Our work is built around the EU AML framework and recognised audit standards, so it aligns with how your national supervisor, and AMLA for in-scope firms, will examine you.
Whether you need a one-off review ahead of a supervisory examination, assurance for an audit committee, or a recurring check on training and QA, we can usually scope and start within weeks.