AML Hiring Costs by Country | The Real Cost to Hire, Part 6

Put the same anti-money laundering (AML) analyst, on the same salary, in Vilnius, Warsaw, Frankfurt, Stockholm and London, and you get five different bills. What changes is how long you can test the hire, who pays when they catch flu, how many days they are away, and what it costs to part ways. National law sets all of that, which is why hiring costs by country differ more than salary benchmarks suggest.

This is Part 6 of The Real Cost to Hire, the first of two parts on culture. It sticks to what the statute books say in Lithuania, Poland, Germany, Sweden and the UK; Part 7 turns to how people communicate, escalate and give feedback.

Why the country line belongs in an AML hiring plan

A payment institution licensed in Vilnius may run transaction monitoring from Poland, report to a group in Germany and have a founder who learnt employment norms in London or outside Europe. Each assumes the rules they grew up with are the normal ones. They are not, and the gap shows up at three moments: the end of probation, the first long sick leave, and the day someone has to go. (We have set out why Lithuania works as a base for AML outsourcing elsewhere.)

Probation: how long you get to find out

• Lithuania: up to three months, and the Labour Code prohibits extending it by agreement (Article 36).

• Poland: a probation contract cannot last more than three months, as the regional labour office guide puts it.

• Germany: an agreed probation of up to six months, during which either side can end the contract on two weeks' notice under section 622 of the Civil Code. Once employment has lasted more than six months, the Dismissal Protection Act applies, in establishments with more than ten employees.

• Sweden: probationary employment of up to six months under section 6 of the Employment Protection Act.

• UK: no legal requirement to have a probation period at all. The real test has been the two-year qualifying period for unfair dismissal claims, which the government plans to cut to six months from 1 January 2027, according to its unfair dismissal factsheet.

In Part 3 we cited research putting time to productivity at about 15 weeks for a same-sector hire. A three-month probation in Vilnius or Warsaw ends around week 13, before a new know your customer (KYC) analyst is at full pace. You decide on potential, not output. In Germany and Sweden you get roughly twice as long.

When it does not work out: notice, severance and who else has a say

Statutory minimums for an employer ending the contract of an analyst with two and a half years' service:

• Lithuania: one month's notice (two weeks if the job has lasted less than a year), plus severance of twice the employee's average remuneration when the contract ends on the employer's initiative without fault on the employee's side, under Article 57 of the Labour Code. Eurofound's summary of Lithuanian notice rules also describes a faster route at the employer's own will: three working days' notice and severance of at least six times average remuneration.

• Poland: one month, the same period the employee would owe, under Article 36 of the Labour Code.

• Germany: one month, to the end of a calendar month. The dismissal must also be socially justified. Where employees have elected a works council, which they can do in any establishment with at least five permanent employees entitled to vote, the council must be heard before every dismissal, and a dismissal without that hearing is invalid under section 102 of the Works Constitution Act.

• Sweden: two months for someone with two to four years' service, and the dismissal has to rest on objective grounds (section 7 of the Employment Protection Act).

• UK: two weeks, a week for each full year once someone has passed two years, according to GOV.UK guidance on notice. At that point the analyst can also bring an unfair dismissal claim.

The costs come in different currencies. Lithuania writes severance for a no-fault exit into the Labour Code. Germany charges in process. The UK is cheap on notice and expensive if the reasoning does not hold up. A manager who knows only one of these systems will misjudge the other four.

Same flu, five different bills

An illustrative case: the analyst is off sick Monday to Friday, works a five-day week, has been employed for more than a month and has not been ill before this year. The share of that week's pay the employer carries by statute:

• Lithuania: the employer pays the first two days at 62.06% to 100% of average pay, and Sodra, the social insurance fund, takes over from day three, according to the Ministry of Social Security and Labour. At the minimum rate, that is about 25% of the week.

• Poland: 80% of pay from the employer, which carries up to 33 days of sickness a year (14 for employees over 50) before the social insurance institution steps in, as Zielona Linia explains. That is 80% of the week.

• Germany: full pay for up to six weeks once the job has lasted four weeks, under section 3 of the Continued Remuneration Act. That is 100%.

• Sweden: the employer pays sick pay at 80% for the first 14 days, minus a waiting-day deduction that equals one day's sick pay on a five-day week, as Försäkringskassan sets out. That is about 64%.

• UK: Statutory Sick Pay from the first day since April 2026, as Acas confirms, at GBP 123.25 a week or 80% of average weekly earnings, whichever is lower, under the 2026 to 2027 rates. Above about GBP 154 a week in earnings, that is a flat GBP 123.25, though many contracts pay more.

The lost output is the same everywhere: a week of reviews that did not get done. The law only decides who absorbs the bill. In Poland the 33-day employer-paid allowance runs per calendar year, so a bad winter lands mostly on your own payroll.

Holidays, and the remote-work line nobody budgets

Statutory annual leave on a five-day week:

• Lithuania: 20 working days, with three more after 10 years of continuous employment, according to the ministry's working time page.

• Poland: 20 days, rising to 26 after 10 years of seniority, where periods of education count towards the total (Zielona Linia).

• Germany: at least 24 working days counted on a six-day week under the Federal Leave Act, which comes to 20 days for someone on five.

• Sweden: 25 days under section 4 of the Annual Leave Act.

• UK: 5.6 weeks, which is 28 days on a five-day week, and the employer may count bank holidays within that.

These are floors. Collective agreements and local market practice often sit above them.

Remote work has its own line in Poland. Under the Labour Code's remote-work rules, the employer has to cover the electricity and telecoms costs needed for remote work, which can be settled as a lump sum, and occasional remote work at the employee's request is capped at 24 days a year, according to the Ministry of Family, Labour and Social Policy. For a mostly remote AML team, budget it from day one.

How to use this when you plan an AML team

• Match probation to ramp-up. In a three-month regime, review at weeks 8 to 10 using quality assurance (QA) results, not impressions.

• Budget sick pay by country, not by head.

• Price the exit before the entry: notice, severance and process.

• In Germany, find out early whether a works council exists.

• With London staff, diary 1 January 2027.

• Write the local rules into the hiring plan. A founder's home-country instinct is not a policy.

Where outsourced analysts fit

With an outsourcing provider, probation, sick pay, notice and severance sit with the provider as employer, and you buy capacity by the hour, the finished case or the processed item. CAML's analysts each have more than five years of AML experience, work under ACAMS-certified Team Leads, and every critical task goes through four-eyes review. Every engagement starts with a one-week onboarding period that sets an agreed key performance indicator (KPI) baseline. The regulated firm still owns oversight of the arrangement, as our guide to what EU supervisors expect from outsourcing explains.

Frequently asked questions

Which country gives the longest probation for an AML hire?

Germany and Sweden allow up to six months. Lithuania and Poland allow three. The UK has no statutory probation, and the unfair dismissal qualifying period falls from two years to six months on 1 January 2027.

Is severance mandatory in Lithuania?

When the employer ends a contract without fault on the employee's side under Article 57 of the Labour Code, yes: twice the employee's average remuneration, or half of it if the job lasted less than a year.

The law is the easy part

Everything above can be checked in an afternoon, and should be rechecked before you hire, because these rules move. The figures reflect the sources as of November 2026; this is not legal advice. The harder costs sit in how people work together across borders. If you need experienced AML capacity without building payroll in five jurisdictions, talk to CAML.

About this series. The Real Cost to Hire is an eight-part series on what AML hiring decisions leave out. Part 1 set out the fully loaded cost of an AML analyst, Part 2 what an empty AML seat costs, Part 3 how long a new AML analyst takes to become productive, Part 4 the cost of a bad AML hire and Part 5 what AML staff turnover and counter-offers cost. Part 7 covers the soft costs nobody budgets: communication styles, escalation habits, feedback culture and distributed teams.