Training and the "fit and proper" person test
Who needs AML/CTF training, how often, and what makes a person fit and proper to handle compliance.
Every reporting entity must train its staff in AML/CTF obligations. The training requirement is set out in the AML/CTF Act 2006 (Cth) and detailed in the AML/CTF Rules 2025.
Who needs training. Anyone whose work brings them into contact with designated services or customers — sales agents, buyer's agents, principals, administrative staff who handle CDD or trust accounting, and the AML/CTF Compliance Officer. The training must be tailored to their role: an agent needs to know how to identify customers and recognise red flags; a Compliance Officer needs to understand reporting and programme obligations in depth.
How often. At minimum on induction, and on a regular cycle thereafter — annually is the conservative standard and is what AUSTRAC inspectors expect. Refresher training is required whenever the law, the Rules, or your programme materially changes.
What it covers.
- The agency's AML/CTF obligations
- Designated services and the customer types your agency deals with
- CDD procedures, including how to identify red flags
- The internal escalation procedure for suspicious matters
- The tipping-off prohibition
- Sanctions screening obligations
- Record-keeping requirements
- The penalties for non-compliance
Evidencing it. Training records must include attendees, dates, content covered, and ideally an assessment component (a short quiz or scenario exercise) so AUSTRAC can see that comprehension was tested. "We sent them the policy" is not training. Online modules with completion tracking are the cleanest evidence.
The AML/CTF Compliance Officer. Every reporting entity must appoint a Compliance Officer — a natural person, employed at management level or above, with sufficient seniority to escalate matters to the principal or board. The Compliance Officer is responsible for the programme, oversees CDD, files SMRs and TTRs, and is the contact point for AUSTRAC.
Fit and proper. The Compliance Officer (and senior staff with AML responsibilities) must be "fit and proper." There is no single statutory definition, but the test addresses honesty, integrity, competence, and absence of disqualifying history (relevant criminal convictions, regulatory findings, bankruptcy in some cases). Reporting entities are expected to perform background checks at appointment and on a periodic basis.
The Compliance Officer role is not nominal — it carries personal accountability and AUSTRAC will engage with that individual directly during any inspection or enforcement action.
Every agent across every office, on an annual training cycle with documented attendance and assessment, generates a continuous evidence trail across the seven-year retention window.
What to do next: Appoint your AML/CTF Compliance Officer in writing, document the appointment, and schedule the first round of induction training before 1 July 2026.