What the law requires
Nothing requires an external course or a certificate. A module written from your own program, with a short test and a recorded result, meets the obligation for a small firm.
- Training for staff whose duties relate to designated services, on commencement and at regular intervals.
- Content that covers the business's obligations, the risks in its risk assessment, the consequences of non-compliance, the procedures in the program and how to escalate a concern.
- Records of who was trained, when and on what.
- Screening of staff in AML/CTF roles.
How often
On commencement for anyone who deals with customers or customer money, then at least annually, and whenever the program changes materially. Record each session; AUSTRAC asks about training in the annual compliance report.
Certifications and courses
The best-known international certification is CAMS from ACAMS; Australian providers offer AML/CTF courses ranging from short online modules to accredited units. These are valuable for compliance officers in larger organisations and for people building a career in financial crime. For a firm of four, the cost and depth are out of proportion; the compliance officer needs to understand the program, not hold a designation.
Training that counts twice
Professional bodies (CPA Australia, CA ANZ, IPA, ICB, the real estate institutes, law societies and AIC) offer AML/CTF sessions that usually count towards continuing professional development. Keep the record; it serves both purposes.
Questions people ask
- Is AML training mandatory in Australia?
- For reporting entities, yes: the program must include staff training and records of it. There is no mandatory certification.
- How long does staff training take?
- For a small firm with a simple risk profile, twenty to thirty minutes per person per year is enough if it covers the program's content and is recorded.
- Do principals and directors need training?
- Yes. Everyone who provides designated services or deals with clients, including principals and the compliance officer.
General information about Australian AML/CTF law, not legal advice. The Act, the Rules and AUSTRAC's guidance are the primary sources.