Appointing your AML/CTF Compliance Officer
Who can be appointed as AML/CTF Compliance Officer, what the role involves, when the appointment must happen, and how to document it correctly.
Every reporting entity must appoint an AML/CTF Compliance Officer before providing designated services. For real estate agencies and buyer's agents, that means the appointment must be in place before 1 July 2026. There is no grace period for this obligation — unlike the AUSTRAC enrolment deadline, the Compliance Officer must exist from day one.
Who can hold the role. The Compliance Officer must be a natural person — not a company, trust, or position title without a named individual. They do not need to be a lawyer or professional compliance specialist. A principal, licensee, director, or experienced agent can fulfil the role. For sole traders, self-appointment is common and entirely permissible.
The fit and proper requirement. The Compliance Officer must be fit and proper. The assessment addresses honesty, integrity, competence, and absence of disqualifying history — relevant criminal convictions, regulatory findings, or undischarged bankruptcy. AUSTRAC does not conduct pre-appointment screening; the assessment and its documentation are your responsibility. At minimum this means a police check, a bankruptcy check via AFSA, and a written declaration from the appointee.
What the role involves.
- Overseeing and maintaining the AML/CTF programme
- Managing internal escalations when staff identify suspicious matters
- Filing suspicious matter reports and threshold transaction reports
- Acting as the primary contact for AUSTRAC during inspections or enquiries
- Ensuring training obligations are met
The Compliance Officer does not need to personally conduct every CDD check. Day-to-day tasks can be delegated. What cannot be delegated is the accountability.
The appointment document. The appointment must be in writing, referenced in your programme, and retained for seven years. It should record the appointee's full name, role, date of appointment, and a statement that they have been assessed as fit and proper. The governing body or principal signs it.
If the Compliance Officer leaves. A replacement must be appointed promptly. Operating as a reporting entity without a current Compliance Officer is a standalone breach of the AML/CTF Rules 2025 and will be treated as an indicator that the programme is not operational.
What to do next: Name your Compliance Officer in writing before 1 July 2026, conduct and document the fit and proper assessment, and reference the appointment in your AML/CTF programme.