# AMLR Art. 12 — Awareness of requirements > GwG Art. 8d has been in force since 1 October 2026. AMLR Art. 12 applies from 10 July 2027. See [[Effective-dates timeline]] and [[The adviser regime (2025 GwG revision)]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.18 - Internal controls and foreign branches and subsidiaries|FATF R.18]] - **Swiss provisions:** [[GwG Art. 8 - Organisational measures (training, internal controls)|GwG Art. 8]], [[GwV-FINMA Art. 27 - Integrity and training|GwV-FINMA Art. 27]] - **Detailed citation:** GwG Art. 8; GwV-FINMA Art. 27 ## What it requires Obliged entities must take measures so that employees or persons in comparable positions whose function requires it, including agents and distributors, are aware of the AMLR/Regulation 2023/1113 requirements, the business-wide risk assessment, and the entity's internal policies, procedures and controls, including on personal-data processing. This includes participation in specific, ongoing training programmes to help them recognise possible ML/TF operations and know how to proceed, appropriate to their function and to the entity's ML/TF risk, and duly documented. ## Swiss position GwG Art. 8 requires financial intermediaries to take the measures necessary to prevent money laundering and terrorist financing in their area, in particular ensuring adequate staff training and controls. GwV-FINMA Art. 27 adds that combating money laundering and terrorist financing requires personnel of integrity and adequate training, and requires the intermediary to select staff carefully and to provide regular training to all affected employees on the aspects material to them. Since 1 October 2026, advisers have a parallel training-and-controls duty under new GwG Art. 8d, which also extends it to preventing breaches of Embargo Act coercive measures. ## Key divergences AMLR Art. 12 is programmatic: it requires specific, ongoing training tailored to function and risk, expressly extends the awareness duty to agents and distributors and to the business-wide risk assessment and internal policies themselves (not only red-flag recognition), and requires documentation of the training programme. GwG Art. 8 states the training and controls duty in a single general clause, and GwV-FINMA Art. 27 adds a careful-selection duty and a regular-training duty, but neither itemises programme content, cadence or documentation to the degree AMLR Art. 12 does. The financial-intermediary duty (GwG Art. 8, GwV-FINMA Art. 27) and the adviser duty (GwG Art. 8d) sit in separate provisions. ## Effective dates GwG Art. 8d has been in force since 1 October 2026. AMLR Art. 12 applies from 10 July 2027. See [[Effective-dates timeline]] and [[The adviser regime (2025 GwG revision)]]. ## Further connections *These links come from an article-by-article comparison of the primary texts. They add to the provisions listed at the top of this note and make no equivalence claim.* - [[GwG Art. 8d - Adviser organisational measures; training and|GwG Art. 8d]] — AMLR Art. 12 requires awareness measures and ongoing, documented, function- and risk-appropriate staff training; GwG Art. 8d (in force 1.10.2026) requires the new adviser category to ensure adequate staff training and maintain controls. *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 12 — English text (EUR-Lex, CELEX 32024R1624) > **Article 12** > *Awareness of requirements* > Obliged entities shall take measures to ensure that their employees or persons in comparable positions whose function so requires, including their agents and distributors are aware of the requirements arising from this Regulation, Regulation (EU) 2023/1113 and any administrative act issued by any supervisor, and of the business-wide risk assessment, internal policies, procedures and controls in place in the obliged entity, including in relation to the processing of personal data for the purposes of this Regulation. > The measures referred to in the first paragraph shall include the participation of employees or persons in comparable positions, including agents and distributors, in specific, ongoing training programmes to help them recognise operations which may be related to money laundering or terrorist financing and to instruct them as to how to proceed in such cases. Such training programmes shall be appropriate to their functions or activities and to the risks of money laundering and terrorist financing to which the obliged entity is exposed, and shall be duly documented. ## Sources - AMLR Art. 12 — CELEX 32024R1624 - GwG SR 955.0, Art. 8 - GwG (rev. BBl 2025 2899, in force 1.10.2026), Art. 8d - GwV-FINMA SR 955.033.0, Art. 27