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AML/CTF training plan and register: what to keep.

AUSTRAC expects a training plan that schedules tailored training for each role, and a register that records completion dates and shows when more training is due. Records must be reasonably necessary to demonstrate that you met the training duty, so keep them together.

Sources for this answer
  • 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]

What goes in a training plan?

  • The roles in your business that perform AML/CTF functions.
  • The training each role gets, tied to its risks.
  • When each person is trained, and when it is repeated.
  • How you check that people understood.
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 lists "Post-training assessment of understanding and testing results to confirm personnel understand key content" as a way to monitor training. [S1]

What goes in a register?

  • Who completed training: names, roles and teams.
  • What training was delivered: topics, format and content version.
  • How understanding was assessed.
  • Completion dates, and when further training is due.
Facts and sources for this part
  • AUSTRAC examples of training records: who completed training (names, roles, teams), what was delivered (topics, format, content version) and how understanding was assessed. [S1]
  • AUSTRAC expects you to "use a register to record completion dates and track when further training is due". [S1]
  • AUSTRAC: "Maintaining a training log or register can help make sure that" all relevant personnel have been trained, you can identify who needs refresher training and you can demonstrate compliance to AUSTRAC. [S1]

How often?

AUSTRAC gives examples only: compliance officers and senior management every 6 to 12 months, customer-facing staff every 12 months. The right frequency is the one appropriate to your business.

Facts and sources for this part
  • 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]
  • AUSTRAC: "The frequency and extent of ongoing training will depend on functions the person performs and the ML/TF risks." [S1]

Where the firm plan helps

The firm plan gives a downloadable register (CSV and PDF) built from your staff’s certificates, and a training plan template to fill in. Your AML/CTF program must still describe your training.

Facts and sources for this part
  • AUSTRAC: "You must keep records that are reasonably necessary to demonstrate compliance with your personnel training obligations." [S1]