Regulation 21 from the Money Laundering Regulations 2007 requires that all relevant staff receive money laundering awareness training when joining a firm and regularly thereafter.  So all who have previously received the Money Laundering Awareness Training (or equivalent) should be considered for the refresher training.  As with the initial training, most staff in a regulated firm are likely to be eligible to receive this training.  The frequency of the refresher training should be determined by the firm’s management using a risk based approach; it may lead to different frequencies for different jobs in the same firm, depending on the risk assessments for the jobs but an annual update suits many and can be administratively managed to fit with other issues such as performance appraisals.