Appointing your AML/CTF Compliance Officer

Every reporting entity must appoint an AML/CTF Compliance Officer. Under the AML/CTF Act 2006 (Cth) ss 26J–26M and AML/CTF Rules 2025 s 5-14, the appointment must be in place within 28 days of starting to provide a designated service, and AUSTRAC must be notified within 14 days of the appointment via the enrolment form on AUSTRAC Online.

For agencies operating from 1 July 2026, that means having the appointment signed and dated before commencement and the AUSTRAC notification lodged shortly after.

Who can hold the role. A natural person — not a company, not a position title, not "the management team." They do not need to be a lawyer or a career compliance specialist. A principal, licensee, director, or senior agent can be appointed. Sole traders typically self-appoint, which is permissible.

The Compliance Officer should be senior enough to escalate matters to the governing body, have authority to file reports without seeking sign-off on each one, and have direct access to the records of the agency's designated services.

The fit-and-proper assessment. The Act and Rules require the appointee to be fit and proper. There is no single statutory checklist, but AUSTRAC guidance points to: honesty and integrity, relevant skills and knowledge, and the absence of disqualifying history — relevant criminal convictions, regulatory findings, or undischarged bankruptcy.

The agency runs the assessment and keeps the evidence. AUSTRAC's published expectation is that this evidence includes open-source searches, credit checks, reference checks, and a police check. A signed declaration from the appointee about prior conduct and current status rounds it out.

What the role does.

• Owns the AML/CTF programme — drafting, approval cycles, version control
• Receives internal escalations of suspicious matters
• Files SMRs, TTRs, and other reports
• Acts as the primary AUSTRAC contact during inspections and enquiries
• Ensures training is delivered, attended, and evidenced

Day-to-day work can be delegated. Personal accountability cannot.

The appointment record. Put it in writing. The document should name the appointee, state the role, record the appointment date, and reference the fit-and-proper assessment evidence on file. The governing body or principal signs it. The programme refers to it by name. Retain it for seven years under s 116 of the Act.

Replacements. If the appointee leaves, a successor must be appointed promptly and AUSTRAC notified. Running without a current Compliance Officer is treated as evidence that the programme is not operational and exposes the agency to enforcement action distinct from any underlying breach.

What to do next. Name your Compliance Officer in writing before 1 July 2026, complete the fit-and-proper assessment, lodge the AUSTRAC notification within 14 days of the appointment, and reference the appointment in the programme.