Key Point
You must provide AML/CTF training to employees who handle designated services or related functions. The format, duration and provider are not mandated - what matters is that staff understand their obligations.
Who Needs Training?
Your AML/CTF program must include provisions for training employees. This applies to:
- Anyone providing designated services to customers
- Staff involved in customer due diligence
- Staff handling transaction monitoring
- The AML/CTF Compliance Officer
- Anyone who might identify suspicious activity
For sole practitioners with no staff, you still need to ensure you have adequate knowledge - this counts as training yourself.
What Must Training Cover?
Core Training Topics
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Overview of obligations
Understanding the AML/CTF Act and reporting entity duties
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Your AML/CTF program
Specific procedures and policies for your business
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Customer due diligence
How to identify and verify customers
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Suspicious matter identification
Red flags and how to escalate concerns
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Record keeping
What records to keep and for how long
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Tipping off
Understanding the prohibition on disclosing reports
How Can Training Be Delivered?
The legislation doesn't mandate a specific format. Acceptable methods include:
- In-house training - delivered by the Compliance Officer or management
- External courses - from training providers or industry associations
- Online learning - self-paced modules or webinars
- Documentation review - structured reading of program materials with assessment
- Combination approach - mix of methods as appropriate
What You DON'T Need
Despite what some providers suggest, there is no requirement for:
- External certification
- Minimum course duration
- AUSTRAC-approved training
- Annual recertification (though regular updates are good practice)
- Expensive third-party courses
Documentation Requirements
You should maintain records of training provided, including:
- Who was trained
- When training occurred
- What topics were covered
- Evidence of completion (sign-off, quiz results etc.)
This doesn't need to be complex - a training register or signed acknowledgment forms are sufficient.
Practical Approach for Small Businesses
- Use your AML/CTF program as the primary training material
- Walk through the documentation with staff
- Discuss real-world examples relevant to your services
- Have staff sign acknowledgment that they've read and understood the program
- Provide updates when procedures change or new risks emerge
Ongoing Training
Initial training isn't enough. Your program should include provisions for:
- Refresher training at appropriate intervals
- Updates when procedures change
- Training for new employees
- Addressing gaps identified through monitoring or audits