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Who must be trained under the AML/CTF duty?

Anyone you employ or engage who performs functions relevant to your AML/CTF obligations: staff, contractors, consultants, volunteers, interns and people employed by service providers you use. Training must fit what each person does, it must start when they start, and it must continue during the job.

Sources for this answer
  • 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 must provide initial training at the start of a person’s employment or engagement. You must also provide ongoing training." [S1]
  • 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]

Who is in scope?

  • People you employ.
  • Contractors or consultants.
  • Volunteers or interns, paid and unpaid.
  • People employed by service providers you use.
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]

Which roles need the deepest training?

AUSTRAC says personnel who run enhanced customer due diligence and investigate suspicious matters need a deeper understanding, and that customer-facing personnel need to know the indicators of suspicious activity and the reporting procedures.

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]

When should training happen?

At the start of employment or engagement, then during it. AUSTRAC also expects training before staff take on new duties that expose them to other risks.

Facts and sources for this part
  • AUSTRAC: "You must provide initial training at the start of a person’s employment or engagement. You must also provide ongoing training." [S1]
  • AUSTRAC expects training "before any personnel conduct new duties that may expose them to other ML/TF risks and AML/CTF functions". [S1]

Senior managers and the governing body

A senior manager must still receive appropriate training. If the business is not an individual, its policies must make sure the governing body is sufficiently informed of its risks.

Facts and sources for this part
  • AUSTRAC: a senior manager "will still need to be able to meet their AML/CTF obligations and receive appropriate training". [S20]
  • The Act (section 26F(4)(a)) says that if the business is not an individual, its policies must deal with "ensuring its governing body is sufficiently informed of the risks of money laundering, financing of terrorism and proliferation financing". [S3]