Built to the AUSTRAC training duty.
Each element of the training duty is shown below with the lesson, test question, certificate field and register column that serve it. This course helps you meet the duty. It does not meet it for you: your own AML/CTF program must still describe your training.
The rule, word for word
- The Act (section 26F(4)(e)) says the AML/CTF policies must deal with "providing training to persons who are employed or otherwise engaged by the reporting entity and who perform, or will perform, functions relevant to the reporting entity’s obligations under this Act in relation to: (i) the risk of money laundering, financing of terrorism and proliferation financing that the reporting entity may reasonably face in providing its designated services; and (ii) the obligations imposed by this Act, the regulations and the AML/CTF Rules on the reporting entity;". [S3]
- The rule on training (AML/CTF Rules 2025, section 5-9(2)): "The AML/CTF policies of the reporting entity must deal with both initial training upon a person’s employment or engagement and ongoing training during a person’s employment or engagement." [S2]
- The rule on how training is tailored (AML/CTF Rules 2025, section 5-9(3)): "The AML/CTF policies of the reporting entity must require that the training provided to a person: (a) is appropriate having regard to: (i) the particular function performed by the person; and (ii) the particular risks of money laundering, financing of terrorism and proliferation financing that are relevant to the person’s function; and (iii) the particular responsibilities of the person under the AML/CTF policies; and (b) is readily understandable by the person." [S2]
Element by element
The first six rows are the Rules. The last four are what AUSTRAC says it expects. The final column is the part no outside course can do for you.
| Duty element | Lesson | Test | Certificate | Register | What your business still does |
|---|---|---|---|---|---|
| Initial training when a person starts Rules 5-9(2); Act 26F(4)(e) [S2] [S1] |
All staff: lessons 1, 3, 4, 5, 7. Front-line, client-facing staff: lessons 1, 2, 3, 4, 5, 7. AML/CTF compliance officer: lessons 1, 2, 3, 4, 5, 6, 7. Senior manager: lessons 1, 2, 3, 4, 6, 7. | Final test at the end of the track | Date issued, certificate number | Completed on | Make the course part of onboarding, and say so in your AML/CTF program. |
| Ongoing training during the engagement Rules 5-9(2) [S2] [S1] [S1] [S1] |
Come back for a refresher: retake your track and get a new certificate. The training record suggests a refresher date 12 months on. | Retake the test for a new certificate | Suggested refresher date on the training record | Refresher due by | Set your own frequency in the plan. AUSTRAC’s intervals are examples only. |
| Appropriate to the person’s function Rules 5-9(3)(a)(i) [S2] [S1] [S1] [S1] |
Four tracks, each with its own lessons: All staff, Front-line, client-facing staff, AML/CTF compliance officer, Senior manager. | Questions drawn only from the pool tagged for the track | Role track | Role track | Put each person on the track that matches their job. |
| Appropriate to the ML/TF risks of their function Rules 5-9(3)(a)(ii) [S2] [S17] |
Lesson 3 (red flags by sector) and the four sector pages. | Red-flag questions for every track | Sector | Sector | Add the findings of your own risk assessment. |
| Appropriate to their responsibilities under your AML/CTF policies Rules 5-9(3)(a)(iii) [S2] [S1] |
Lesson 6 explains the roles in a program. It cannot teach your own policies. | Not tested: it is your own program | Not covered | Not covered | Teach your own policies and procedures. No outside course can do this for you. The training plan template has a section for it. |
| Readily understandable by the person Rules 5-9(3)(b) [S2] [S1] [S1] |
Short lessons in plain English, each part ending with what to remember. | Every answer is explained | Not applicable | Not applicable | Check each person’s comprehension and language needs. |
| A training plan, scheduled by role AUSTRAC guidance [S1] |
Not a lesson topic | Not applicable | Not applicable | Not applicable | Firm plan: fill in the training plan template (free here too). |
| A register of completion dates and when training is next due AUSTRAC guidance [S1] [S1] |
Not a lesson topic | Not applicable | Date issued | The whole register (CSV and PDF) | Firm plan: download it any time and keep it. |
| Records reasonably necessary to demonstrate compliance with the training duty AUSTRAC guidance [S1] [S1] |
Not a lesson topic | Test result kept with the certificate | Certificate and training record (PDF) | Certificate number, with a public check | Keep the records in line with your program. |
| Check that people understood AUSTRAC guidance [S1] [S6] |
Not a lesson topic | Pass mark 80% (16 of 20) | Score on the training record | Score | Review results and give more training where needed. |
What this course does not do
- It is not approved by AUSTRAC and it does not make a business compliant.
- It does not teach your own policies, procedures or risk assessment.
- It does not decide how often each person is trained. Your plan does.
- It does not replace personnel due diligence, independent evaluations or reporting.
See the firm plan with a register Open the training plan template