Training and the fit-and-proper test

Every reporting entity must train its staff. The training requirement sits inside the programme obligations in the AML/CTF Act 2006 (Cth) and is detailed in the AML/CTF Rules 2025.

Who needs training. Anyone whose work brings them into contact with a designated service or with customers being onboarded: sales agents, buyer's agents, principals, administrative staff who handle CDD or trust accounting, and the Compliance Officer. Content must be calibrated to the role. An agent needs to spot red flags and run the CDD process; a Compliance Officer needs to know reporting and programme obligations cold.

How often. The statute does not name a frequency. AUSTRAC's expectation is induction training plus a regular refresher cycle. Annual is the working standard. Refresh sooner when the Act, the Rules, or your programme changes in a way that affects how staff do their jobs.

What it covers.

• The agency's obligations under the Act and Rules
• The designated services the agency provides and the customer types it deals with
• CDD procedures and red flags
• The internal escalation path for suspicious matters
• The tipping-off prohibition (Act s 123)
• Sanctions screening (DFAT Consolidated List)
• Record-keeping requirements
• Civil penalty exposure

Evidencing it. Training records must show attendees, dates, content covered, and ideally an assessment component — a short quiz, a scenario exercise, anything that demonstrates comprehension was tested. Online modules with completion tracking are the cleanest evidence. Distributing a policy document and calling it training is not training.

The Compliance Officer. A natural person, appointed in writing, employed at sufficient seniority to escalate matters to the principal or board. The Compliance Officer owns the programme, oversees CDD, files SMRs and TTRs, and is the AUSTRAC contact point during inspections. The role is not nominal — it carries personal accountability and AUSTRAC will engage with that individual directly during any inspection or enforcement action.

Fit and proper. The Compliance Officer, and senior staff with AML responsibilities, must be fit and proper. There is no single statutory definition. The assessment addresses honesty, integrity, competence, and the absence of disqualifying history — relevant criminal convictions, regulatory findings, or undischarged bankruptcy.

AUSTRAC's published expectation is that the agency documents the assessment with evidence: open-source searches, credit checks, reference checks, and a police check. Re-check on a sensible cycle and on any material change in circumstance.

What to do next. Appoint your Compliance Officer in writing, complete and file the fit-and-proper evidence pack, and schedule induction training for everyone in scope before 1 July 2026. Diarise the first refresher round for twelve months out.