AML training programs should extend beyond basic concepts to deliver targeted training by:

Targeted training extends beyond foundational AML concepts by making the material directly relevant to an employee's specific job functions and responsibilities. The most effective method to achieve this is by tailoring the training content to the individual's specific role within the institution. For example, front-line staff receive training focused on identifying red flags in customer transactions, while compliance investigators receive advanced training on alert handling and SAR narrative writing. This role-specific approach ensures that the training is practical, actionable, and directly enhances the employee's ability to contribute to the AML/CFT program, which is the core principle of targeted training.

A. While training on internal policies is a critical component of an AML program and is more specific than general concepts, it is a type of content delivered within a targeted framework, not the overarching methodology of targeting itself.
B. Offering general background and history is the definition of basic, non-targeted training, which the question explicitly asks to move beyond.
C. This option describes the frequency and audience for refresher training but specifies the content as "AML bases," which is foundational rather than targeted to specific roles.

1. ACAMS CAMS 6th Edition Study Guide. In Chapter 4, "AML/CFT Compliance Program," the section "Who to Train and How to Train" explicitly states, "The training should be targeted to different audiences." It provides examples such as training tellers to recognize red flags and training personnel on how to draft SARs effectively, which directly aligns with the principle of role-specific training described in option D. (p. 133).

2. The Wolfsberg Group, "Guidance on an Effective AML/CTF Programme" (October 2022). Page 15 states that an effective training program should be "tailored to the specific risks faced by the FI and the role of the individual employee, taking into account their seniority and function." This directly supports tailoring training to specific roles as the key to making it targeted and effective.

3. Financial Action Task Force (FATF), "Guidance for a Risk-Based Approach for the Banking Sector" (October 2014). Paragraph 131 emphasizes that AML/CFT training should be "appropriate to the role of the staff member" and delivered at "levels of detail appropriate to the audience." This reinforces the international standard that effective training is targeted and role-specific.