What training must cover
- Your firm's obligations under the AML/CTF Act and what a designated service is.
- How to identify and verify clients and beneficial owners.
- The red flags that should be escalated to the compliance officer.
- Reporting: suspicious matters, threshold transactions, and the tipping-off rule.
- Record keeping.
- The consequences of getting it wrong, for the firm and for the individual.
How often
On commencement for anyone who deals with clients or client money, then at least annually, and whenever the program changes materially.
What to record
Who was trained, when, on what, and the result if there was a test. AUSTRAC asks about training in the annual compliance report and will ask for the records in a review.
A practical format
A short module with a handful of questions, passed at a set mark, recorded with a date, repeated yearly. Twenty minutes per person per year is enough for a small practice with a simple risk profile.
Questions people ask
- Do partners need training too?
- Yes. Everyone who provides designated services or deals with clients, including principals and the compliance officer.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.