Who has to train staff, and from when?
Real estate agents, accountants, lawyers, conveyancers, trust and company service providers and dealers in precious stones and metals are newly regulated for anti-money laundering and counter-terrorism financing (AML/CTF). AUSTRAC says they are regulated from 1 July 2026.
Once you provide a designated service, you are a reporting entity. Training your people is one of the things your AML/CTF program must cover.
Remember
- The newly regulated sectors are regulated from 1 July 2026.
- Training is part of your AML/CTF program, not an optional extra.
Facts and sources for this part
- AUSTRAC says businesses that provide the newly regulated services "will be regulated by us from 1 July 2026". [S36]
- AUSTRAC names the newly regulated businesses: real estate professionals, dealers in precious stones, metals and products, lawyers, conveyancers, accountants and trust and company service providers (and some virtual asset businesses). [S36]
What do the rules actually say about training?
The Act says your AML/CTF policies must deal with training for people who perform functions relevant to your AML/CTF obligations. The training must cover your money laundering and terrorism financing risks, and your obligations under the Act, regulations and Rules.
The AML/CTF Rules add two requirements: training at the start and during the job, and training that fits the person. Read the exact words in the facts box below.
Remember
- Initial training when someone starts, and ongoing training after that.
- Training must fit the person’s function, the risks of that function and their responsibilities.
- It must be readily understandable by the person.
Facts and sources for this part
- 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]
Who counts as “staff” for this duty?
More people than you might think. AUSTRAC says the duty covers people you employ and people you otherwise engage, including contractors, consultants, volunteers, interns and people employed by service providers you use.
The test is function, not job title. If your work touches customers, money, records, reports or the AML/CTF program, assume you are in.
Remember
- Employees, contractors, interns and volunteers can all be in scope.
- Function matters more than job title.
Facts and sources for this part
- AUSTRAC: the duty covers people you employ and people you otherwise engage, such as contractors or consultants, volunteers or interns (paid and unpaid) and people employed by service providers you use. [S5]
- AUSTRAC: you may give general training to all personnel, but if roles have different AML/CTF functions and risk levels, "you must include appropriate training for individuals exposed to these different risks". [S1]
Why is there more than one training track?
Because AUSTRAC expects training to fit the role. Everyone who deals with customers needs to spot suspicious activity and know how to report it. People who run enhanced checks or investigate suspicions need a deeper understanding.
This course has four tracks: all staff, front-line client-facing staff, the AML/CTF compliance officer and senior managers. You pick yours before the test, and the questions come only from your track.
Remember
- Pick the track that matches your job.
- Customer-facing staff must know the red flags and the reporting steps.
- Deeper roles need a deeper understanding.
Facts and sources for this part
- AUSTRAC: "All personnel in customer-facing roles need an awareness of indicators of suspicious activity and your reporting procedures." [S1]
- AUSTRAC: personnel who do enhanced customer due diligence and investigate suspicious matters "need a deeper understanding of the ML/TF risks your business faces and procedures they must follow". [S1]
What does your business still have to do?
AUSTRAC expects a training plan that schedules role-based training, and a register that records completion dates and shows when more training is due. It also expects you to keep records that are reasonably necessary to show you met the training duty.
A course can supply the training, the test result and the certificate. Your AML/CTF program must still describe your own training, and your people must also learn your own procedures. No outside course does that part for you.
Remember
- Keep a training plan and a register.
- Keep records that show you trained people.
- Your own program and procedures must be taught too.
Facts and sources for this part
- AUSTRAC expects you to "develop a training plan and schedule tailored training to different roles and their relevant ML/TF risks". [S1]
- AUSTRAC expects you to "use a register to record completion dates and track when further training is due". [S1]
- AUSTRAC: "You must keep records that are reasonably necessary to demonstrate compliance with your personnel training obligations." [S1]
- AUSTRAC: "Avoid relying on generic training not specific to your industry without first assessing if it’s appropriate for your business and adapt it as needed." [S1]
Check what you have learned
Three questions from the test, each explained. Tap an answer.
Question 1 of 3
Which of these businesses is on AUSTRAC’s list of newly regulated businesses?
Show the answer
Right answer: B, A conveyancer. AUSTRAC lists real estate professionals, dealers in precious stones and metals, lawyers, conveyancers, accountants and trust and company service providers. [S36]
Question 2 of 3
Under rule 5-9(3), training must be readily understandable by whom?
Show the answer
Right answer: A, The person receiving it. Paragraph (b) says the training must be readily understandable by the person. [S2]
Question 3 of 3
Can a small business give every member of staff the same general AML/CTF training?
Show the answer
Right answer: D, Only if roles do not differ in function and risk; otherwise training must fit the different risks. AUSTRAC says general training is allowed, but where roles have different functions and risk levels you must include appropriate training for the people exposed to those risks. [S1]