The format is open under the law: the German Money Laundering Act (GwG) does not prescribe whether GwG training takes place as e-learning or in the classroom. What matters is the content and risk-based delivery, not the method.
Section 6 (2) no. 6 GwG lists among the internal safeguards "the initial and ongoing training of employees with regard to the typologies and current methods of money laundering and terrorist financing and the relevant regulations and obligations in this respect, including data protection provisions". The provision does not name a specific format – nor a rigid frequency.
The Interpretation and Application Guidance (AuA) of BaFin, whose general part applies from February 1, 2025, specifies this: training can be delivered in classroom training sessions or by using IT-based training programs (e-learning) that are appropriate in content and up to date. The obliged entity decides on the types, design, scope, and timing on a risk-based basis and independently – appropriate to the individual risk situation, regularly and as the occasion requires. How often training is specifically required is put into context in the article on the GwG training obligation under Section 6 GwG ; further material is available in the money laundering prevention topic area.
In terms of content, the training must cover at least typologies and current methods of money laundering and terrorist financing, the relevant obligations of employees, and the data protection provisions mentioned. How in-depth and how often training takes place depends on the obliged entity's risk situation – a role with customer contact needs a different level than an activity with no connection to transactions relevant to money laundering. The format is a means to an end, not an end in itself.
Note: The BaFin AuA are aimed primarily at the financial sector; in the non-financial sector, the respective competent supervisory authorities of the federal states are decisive. However, the format-neutral, risk-based underlying logic is transferable. This article is a general overview, not legal advice.
In short: e-learning scores on scaling, standardization, and proof; classroom training on interaction and complex roles. The following overview compares the key dimensions (general subject-matter and didactic assessment, not a legal requirement):
| Dimension | E-learning | Classroom training |
|---|---|---|
| Scalability | high – independent of location and time, many sites in parallel | limited – dependent on scheduled dates, per group on site |
| Proof / documentation | can be automated (participation, progress, and test logs in the LMS), can be evaluated per person | manual (attendance lists, agenda) – more laborious and more error-prone |
| Ease of updating when the law changes | central and fast – new typologies/provisions in one version for everyone | dependent on scheduling and trainer availability |
| Standardization / consistency | high – identical content and quality for all employees | dependent on the trainer and their form on the day |
| Interaction / questions | limited – asynchronous: scenarios and comprehension questions in the course, questions via fixed contact and escalation channels | high – discussion, case-related questions, exercises |
| Flexibility of time and location | high – in the flow of work, suitable for shift work and working from home | low – fixed dates, attendance required |
| Costs / effort | higher initial investment, low marginal costs per person | recurring fixed costs per session (trainer, room, working time) |
| Suitability | broad-based training, basic knowledge, many/dispersed employees | complex, role-specific content, key functions |
| Typical limitations | Depth and commitment depend on the instructional design; scenarios, mandatory tests, and a mandatory learning path must be deliberately built in | Reach and repeatability are limited; record-keeping and making up missed sessions must be organized manually |
Classified as general subject-matter/didactic knowledge, not as a legal requirement; the specific weighting follows the obliged entity's individual risk situation.
A basic pattern emerges from the table: e-learning is strong where reach, uniformity, and complete proof matter; classroom training is strong where understanding develops through dialogue, casework, and questions. No single dimension decides on its own – only weighting them by role, size, and risk leads to the right choice of format.
What matters is not only that training takes place, but that the training can be evidenced. Training is part of the internal safeguards under Section 6 GwG; appropriate risk management must be documented and traceable for the supervisory authority. This is exactly where the biggest practical difference between the two formats lies.
E-learning generates the records automatically and uniformly: participation status, time spent, and test result are logged in the learning management system (LMS) and can be archived in a traceable manner. Mandatory comprehension questions and final tests can additionally demonstrate that content was not merely "clicked through" but understood. In the classroom, proof is created via attendance lists, agendas, and test sheets – it must be produced, collected, and retained manually, which is more laborious and more error-prone. For both formats: without verifiable documentation, fulfillment of the training obligation cannot be demonstrated in case of doubt.
In the event of an audit, what counts is how quickly and completely the training can be evidenced. An LMS makes it possible to show, without manual compilation, which employees completed which training when and with what result – including open cases and reminders. This ability to evaluate is an advantage in its own right over manually kept records, especially with larger and dispersed workforces.
Not only the training content but also the training itself touches on data protection – Section 6 (2) no. 6 GwG expressly names the data protection provisions as a subject of the training. With e-learning, there is the added factor that an LMS processes personal participation and test data: who completed which course when and with what result? These data are necessary for proof but are at the same time subject to the GDPR – purpose limitation, deletion periods, and access rights should be regulated. A central system makes it easier to enforce these requirements uniformly instead of managing them across scattered lists and mailboxes.
For retention: records of the internal safeguards must be kept in such a way that they remain traceable for the supervisory authority. An LMS handles logging and archiving largely automatically; with classroom training, attendance lists, agendas, and records must be filed manually and kept available for the retention period. Both approaches are permissible – the difference lies in the effort and the susceptibility to error.
E-learning plays to its strengths above all when it comes to breadth. An e-learning course for anti-money laundering training reaches many employees at dispersed sites consistently and in the same quality, can be updated centrally and quickly when new typologies or legal changes arise, and automatically generates the records for documentation vis-à-vis the supervisory authority. It is independent of location and time and fits into shift work and working from home. Updates reach all employees in the same version without the need to coordinate dates.
Limitations lie in the lower spontaneous interactivity and in the fact that complex, case-related questions are harder to address in a self-study format; how much depth a course achieves also depends on the instructional design. This is exactly what scenario-based cases, mandatory tests, and clear guidance on whom employees should contact in the event of specific grounds for suspicion address – for example the AML officer; a mandatory learning path with a final test at the same time records progress in a verifiable way.
Classroom training scores on interaction and commitment. Questions, discussion, and case-based exercises are particularly suitable for complex or role-specific content – for example for AML officers, sales staff with direct customer contact, or risk-exposed areas such as trading in high-value goods. In the classroom, new typologies can be discussed on the basis of current cases and industry-specific gray areas can be assessed together. Personal exchange also promotes commitment and makes spontaneous questions immediately possible; uncertainties and misunderstandings can thus be cleared up during the session before they become entrenched in everyday work.
The price for this is higher organizational effort, poorer scalability across multiple sites, dependence on scheduled dates, and manual and therefore more error-prone record-keeping. The larger and more dispersed the workforce, the more heavily these disadvantages weigh.
The training must be ongoing and cover "current methods" – so content has to evolve with them. Section 6 (2) no. 6 GwG expressly requires ongoing training; among the triggers for event-driven training, BaFin names new statutory rules, significant changes in administrative practice, and findings on new forms of money laundering (see also definition of money laundering).
This is where e-learning has a structural advantage: new typologies, changed deadlines, or a new legal situation can be entered centrally in one version, which all employees then receive. Classroom training sessions have to be rescheduled and held again for this. Especially with a view to the upcoming switch to the EU Anti-Money Laundering Regulation (see below), the ability to update quickly is a factor that goes beyond pure didactics. Reminder and escalation logic – such as automatic follow-up emails to participants who are behind – can also be mapped centrally in e-learning, whereas in the classroom it involves considerable organizational effort.
When it comes to costs, the picture reverses with the number of people to be trained. Classroom training sessions incur recurring fixed costs per session (trainer, room, working time, travel if applicable); the effort increases with each additional group. E-learning has higher initial costs for introduction and maintenance, but low marginal costs per additional person – the cost advantage grows with the number of employees. Added to this is the indirect effort: classroom sessions tie up the working time of several people at the same time, whereas asynchronous e-learning can be fitted more flexibly into everyday work and reduces downtime.
For small teams concentrated at one site with few key roles, classroom training may be sufficient and can establish a direct connection to everyday work; however, the documentation of participation and content must then be safeguarded organizationally, because it is not generated automatically in this format. For small and medium-sized enterprises (SMEs) with several sites, shift work, or dispersed teams, e-learning scales significantly better while keeping record-keeping lean. Company size and structure are therefore often the decisive factor in practice.
The answer depends less on the format than on role and risk. Broad basic knowledge for the entire workforce can be taught efficiently via e-learning. In-depth, role-specific content for key functions benefits from classroom training or a workshop.
For example, the AML officer under Section 7 GwG – to be appointed at management level – as a rule needs a deeper, case-based qualification than the general awareness level. Risk-exposed areas in which employees must recognize red flags and respond correctly are also good candidates for interactive formats. For the rest of the workforce, standardized, verifiable e-learning training is as a rule the right choice: the same level for everyone, kept up to date centrally and – provided the participation and test logs are maintained and retained – fully verifiable.
How differently the right approach turns out is already shown by the range of obliged entities under Section 2 GwG: it extends from credit institutions, financial services providers, and insurers to traders in goods, real estate agents, and gambling providers and on to certain legal and tax advisory professions. A retailer with branches across the country has different requirements for scaling and proof than a small law firm with few employees – the choice of format differs accordingly.
Regardless of the format, effectiveness often fails at the same points. In e-learning, the design of the course is decisive: if scenario-based cases and mandatory comprehension tests are missing, it remains a matter of "clicking through" without verifiable learning success, and without a fixed update cycle, the content does not keep pace with new typologies. Precisely these elements provide the remedy; a professionally maintained course should contain them and map the learning path as well as proof of participation in the LMS – this is something to look out for when choosing.
In classroom training, the typical weak points are incomplete attendance documentation, inconsistent content depending on the trainer and date, and employees who miss the session and are not systematically made to catch up. Anyone using classroom training should document participation and content just as consistently, because this documentation is not generated automatically there – this is something to look out for in the organization so that the didactic advantage does not come at the expense of verifiability. A blended approach can compensate for both weaknesses if the classroom components are documented just as carefully as the digital ones.
The choice is not a matter of faith but a risk decision – and it must be documented. A proven pattern (industry practice, not a legal requirement) is a blended approach:
An example from practice: an SME retailer with several branches trains the entire workforce annually via e-learning on the fundamentals and current typologies and, for the AML officer and cash-intensive sales, adds a classroom workshop with current cases. What matters is that the type and scope match the risk situation and that delivery can be evidenced – as required by Section 6 GwG and the BaFin AuA. The allocation made – which group receives which format – should be briefly justified and documented with a link to the risk analysis so that it remains traceable in the event of an audit.
Until July 10, 2027, the GwG remains decisive; only then does the EU Anti-Money Laundering Regulation apply directly. With the AMLR (Regulation (EU) 2024/1624), the training obligation is spelled out at EU level: Art. 12 AMLR (awareness and training) requires obliged entities to make specific, ongoing training programs mandatory for the employees concerned, so that they recognize transactions suspected of money laundering and know how to proceed.
The format-neutral, risk-based logic thus remains – the importance of documented, ongoing training is likely to increase; a one-off onboarding training session is likely, as a rule, not to meet the standard of ongoing training. Art. 12 AMLR also requires the measures to be proportionate to the nature and size of the company and to be documented – without documentation, fulfillment cannot be proven. The trend is thus clearly toward structured, recurring, and verifiable training programs. The provision does not prescribe the means by which companies organize such programs; an LMS is a widespread but not the only option. Until the AMLR applies, however, the training obligation continues to be governed by the GwG; the AMLR requirements outlined here are an outlook and not yet applicable.
If you do not want to design and continuously maintain the recurring mandatory GwG training yourself, you can use a ready-made, professionally maintained e-learning course instead of developing your own and roll it out via your own learning management system (LMS); whether this pays off depends on the size of the workforce, the sites, and the specialist resources available internally. A note on our own behalf: Bridgly provides a standardized GwG e-learning training course for this mandatory topic, including proof documentation – details on the GwG training service page. In this case, the effort for creating and continuously updating the content lies with the provider; the records are generated in the LMS used and must continue to be maintained and retained there – regardless of whether individual key roles are additionally trained in the classroom.
Neither. Section 6 (2) no. 6 GwG requires initial and ongoing training of employees but leaves the format open. The BaFin AuA expressly name both classroom training sessions and suitable, up-to-date IT-based programs; the obliged entity decides on the type, scope, and timing on a risk-based basis and independently, appropriate to its individual risk situation.
Yes, provided the records generated in the process are maintained and retained. Participation, progress, and test logs from an LMS are well suited as reliable proof of the training – a practical advantage over manual attendance lists. It is important that the documentation is complete, dated, and archived and that the participant data processed is handled in compliance with data protection law, so that fulfillment of the obligation remains verifiable to the supervisory authority.
In practice, blended learning has proven its worth: e-learning for regular broad-based training of all employees, classroom training or workshops for key roles such as AML officers and risk-exposed areas. What matters is not the format itself but that scope and depth match the risk situation and that delivery is documented in a traceable way.
From July 10, 2027, the EU Anti-Money Laundering Regulation (AMLR) applies directly. Art. 12 AMLR requires specific, ongoing training programs that are proportionate to the nature and size of the company and documented; a one-off onboarding training session alone is likely, as a rule, not to meet the standard of ongoing training. The format-neutral, risk-based logic remains – until then, however, the GwG continues to be decisive.
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