AUSTRAC expects reporting entities, including AFS licensees, to provide ongoing AML/CTF training to all relevant staff to ensure they understand ML/TF risks, their specific obligations, and how to identify and report suspicious matters. Training must be risk-based, role-specific, regularly updated, and documented as part of the AML/CTF program.
Expanded Answer
AUSTRAC expects AML/CTF programs to include a documented training framework that ensures staff are competent to perform their roles in managing ML/TF risk. Training must cover the entity’s AML/CTF policies and procedures, customer due diligence requirements, suspicious matter identification and reporting, and the consequences of non-compliance. The scope and depth of training should reflect the staff member’s role and exposure to ML/TF risk.
In practice, AFS licensees should deliver induction training for new staff and ongoing refresher training at defined intervals. Higher-risk roles, such as advisers, client onboarding staff, and compliance personnel, require more detailed and scenario-based training. Training should also be updated when there are changes to regulation, business activities, or identified control weaknesses. Records of training completion, content, and attendance must be maintained.
Regulatory scrutiny increases where training is generic, infrequent, or not aligned to actual business risks and processes. AUSTRAC assesses whether staff can demonstrate understanding in practice, particularly in identifying and escalating suspicious matters. Weak training frameworks are a common contributor to ineffective AML/CTF programs, as outlined in five AML questions you must be able to answer and why AML programs fail adviser audits.
Why it matters
Inadequate training increases the risk of missed suspicious activity, poor customer due diligence, and breaches of AUSTRAC reporting obligations. Regulators focus on whether staff behaviour reflects training, making ineffective training a key driver of enforcement risk.
Practical guidance
- Develop a documented AML/CTF training program aligned to staff roles and ML/TF risk exposure
- Deliver induction and regular refresher training, updating content for regulatory and business changes
- Maintain detailed training records and test staff understanding through scenarios or compliance reviews
Further reading
Five AML questions you must be able to answer
Why AML programs fail adviser audits