AML/CTF training plan template.
A plain template to print or copy. AUSTRAC expects a training plan that schedules role-based training. Fill it in, keep it with your register and describe it in your AML/CTF program.
1. Who performs AML/CTF functions?
List employees, contractors, consultants, volunteers, interns and people at service providers you use.
| Name or role | Track | First training by | Refresh every | Done on |
|---|---|---|---|---|
2. Tracks in this course
- All staff. Lessons: The training duty, and what it means for you; Red flags in your sector; Suspicious matter reports and tipping off; Record keeping and cash reports; Emerging risks: AI scams and fraud.
- Front-line, client-facing staff. Lessons: The training duty, and what it means for you; Knowing your customer: due diligence; Red flags in your sector; Suspicious matter reports and tipping off; Record keeping and cash reports; Emerging risks: AI scams and fraud.
- AML/CTF compliance officer. Lessons: The training duty, and what it means for you; Knowing your customer: due diligence; Red flags in your sector; Suspicious matter reports and tipping off; Record keeping and cash reports; Your AML/CTF program, officer and senior managers; Emerging risks: AI scams and fraud.
- Senior manager. Lessons: The training duty, and what it means for you; Knowing your customer: due diligence; Red flags in your sector; Suspicious matter reports and tipping off; Your AML/CTF program, officer and senior managers; Emerging risks: AI scams and fraud.
3. Your own policies and procedures
Training must fit the person’s responsibilities under your AML/CTF policies. List what you will teach in person or on the job.
| Procedure | Who needs it | How taught | By when | Done on |
|---|---|---|---|---|
4. Checking understanding
AUSTRAC lists post-training assessment, incident reviews and staff feedback. Note what you will use and what you do if someone needs more training.
| Check | How often | Who | Result | Action |
|---|---|---|---|---|
- 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 gives examples (not rules) of how often to train: compliance officers and senior management every 6-12 months, customer-facing personnel every 12 months. [S1]
- AUSTRAC says its frequency examples "are examples only, and the frequency you deliver training must be appropriate to your business". [S1]