Sep 18 / Despoina Charalampous

Complete Guide to Prepare a Compliant AML Manual in 2026

about the author

Despoina is a Maritime Affairs Officer at the Shipping Deputy Ministry of Cyprus, contributing to strategic development and regulatory alignment in the maritime sector.

With over five years of experience in regulatory compliance for financial services, she has supported Cyprus Investment Firms, CASPs, and other CySEC-regulated entities.

She also serves as a Course Instructor at IforPE and Associate of SALVUS Funds, designing CPD courses for compliance professionals. Her combined experience in enforcement and education provides valuable, up-to-date insights to those navigating evolving regulatory frameworks.
An effective Anti-Money Laundering (AML) Manual is a fundamental component of a regulated entity’s AML/CFT compliance framework. It should clearly set out the policies, procedures, controls and responsibilities through which a firm identifies, assesses and manages money laundering and terrorist financing risks.

For regulated financial services firms, preparing and maintaining an AML Manual requires more than documenting standard procedures. The Manual should reflect the firm’s activities and risk profile while addressing areas such as policy development, risk assessment, customer due diligence, reporting procedures and ongoing monitoring. It should also remain aligned with current regulatory requirements and CySEC expectations.


In this blog post, Despoina Charalampous, Associate of SALVUS Funds and an instructor at the Institute for Professional Excellence,  introduces the key themes covered in the online course “Complete Guide to Prepare a Compliant AML Manual in 2026.” The course provides professionals with practical guidance on creating and maintaining a comprehensive AML Manual and strengthening the effectiveness of the AML Function within an obliged entity.   

By completing the course, participants will develop a clearer understanding of the main elements that should form part of an AML Manual, the responsibilities of the AML Function, and the practical considerations involved in maintaining AML policies and procedures in line with CySEC expectations.

The Role of AML Manual

An AML Manual provides the framework through which an obliged entity documents and implements its approach to preventing and detecting money laundering and terrorist financing.

It should translate applicable AML/CFT requirements into practical internal policies and procedures that can be followed across the organisation. This includes defining how risks are assessed, how customers are accepted and subject to due diligence, how transactions and business relationships are monitored, and how potentially suspicious activity is identified and reported.

A well-developed Manual should therefore operate as a practical compliance document rather than simply a statement of regulatory obligations. It should support the AML Function and relevant employees in consistently applying the firm’s AML/CFT framework throughout the customer relationship.

Risk Assessment and Customer Due Diligence

A key component of an effective AML Manual is the firm’s approach to identifying and managing money laundering and terrorist financing risks.
 
 The Manual should establish how the organisation applies its risk-based approach and how this affects the level of customer due diligence undertaken. Appropriate procedures should address customer identification and verification, the assessment of relevant risks and the information required to understand the nature and purpose of the business relationship.

The course specifically addresses risk assessment and customer due diligence as core components of developing a robust AML Manual, helping professionals understand how these areas should be incorporated into the organisation’s documented AML framework.

The AML Function and Regulatory Compliance

The effectiveness of an AML framework depends not only on documented procedures but also on clearly established responsibilities within the organisation.

Professionals involved in the AML Function need to understand their duties and responsibilities and how the firm’s AML policies, controls and procedures should operate in practice. The AML Manual provides an important reference point by documenting the framework through which those responsibilities are performed and monitored.

For Cyprus-regulated firms in particular, maintaining an appropriate AML Manual is an important component of the overall compliance arrangements of Cyprus Investment Firms (CIFs), Crypto-Asset Services Providers (CASPs) and other regulated entities. The course is designed specifically for professionals holding key positions within these types of organisations.

What is the “Complete Guide to Prepare a Compliant AML Manual in 2026” course and what does it include? 

Delivered by Despoina Charalampous, Associate of SALVUS Funds, through the IforPE platform, the “Complete Guide to Prepare a Compliant AML Manual in 2026” has been developed to provide professionals with the knowledge and practical insight required to create and maintain a compliant AML Manual.

This self-paced course is particularly relevant to Anti-Money Laundering Compliance Officers, Compliance Officers and Assistants, as well as professionals working at Cyprus Investment Firms and other CySEC-regulated entities. It is also designed for professionals holding key positions within CIFs, CASPs and other regulated entities who are involved in the development or implementation of AML procedures.

By completing the course, participants will strengthen their understanding of the duties and responsibilities of the AML Function and develop the skills required to draft and maintain an AML Manual in accordance with current compliance standards and regulatory expectations. Participants will also learn how to identify gaps within existing AML processes and incorporate relevant best practices.

The course focuses on the following areas:

  • Purpose and Contents 
- Scope of the Manual​ 
- Version control and documentation
- Terms and Definitions
- Company information
- Contents

  • Money Laundering (ML) and Terrorist Financing (TF) 
- What is Money Laundering (ML)?
- The phases/stages of Money Laundering (ML) and examples
- What is Terrorist Financing (TF)?
- Differences between ML and TF
- Similarities between ML and TF
- Supervisory Authority
- Powers of the Supervisory Authority

  • Legislation 
- National Legislation 
- European Legislation
- Sanctions 
- High-risk jurisdictions  

  • Anti-Money Laundering (AML) Function
- Responsibilities 
- Effectiveness, permanence & independence
- Organizational requirements
- Board of Directors
- Monitoring obligations
- AML Function – Q&As
 

  • AML Manual; Risk Based Approach (RBA) & Customer Due Diligence (CDD) 
- Risk Based Approach (RBA) 
- Customer identification and due diligence
- Clients’ economic profile

  • AML Manual; KYC policy and documentation  
- Policies & Procedures – Compliance tips 
- Client Acceptance Policy
- KYC Policy
- KYC process
- KYC documentation

  • AML Manual; Procedures and Reporting  
- Ongoing monitoring 
- Record keeping 
- Suspicious transactions 
- Reliance on third parties
- Cash deposits
- Rejected – terminated accounts 
- Branches & Subsidiaries
- Regulatory Reporting  
- Staff education and training
- Appendices     

The course is delivered through online video recordings and downloadable PDF study material, allowing professionals to learn whenever and wherever it suits them best. Participants can progress at their own pace, revisit topics as needed and reinforce their knowledge through accessible and structured learning resources.

Upon successful completion, participants receive a certificate awarding 5 CPD hours, recognised by CySEC, the Central Bank of Cyprus, and other professional supervisory bodies. The course contributes towards the annual CPD requirements of CySEC Advanced, Basic and AML Certification holders, as well as professionals registered with ICPAC and the Cyprus Bar Association.
Get in touch
If you have any questions about Despoina's course or any other questions related to your training requirements, please contact us; 
we would love to help.
From all of us at IforPE, the Institute for Professional Excellence,
Ancora Imparo