Knowing what to look for is the first line of defence against money laundering. Training your staff — and proving you did — is a legal obligation.
Under the AML/CTF Act, your AML/CTF program must include an employee training program. Every staff member with AML/CTF-relevant responsibilities must receive training that is appropriate to their role — and you must be able to document that they received it.
At a minimum, training must cover:
Training must be role-appropriate and current. A receptionist who never interacts with clients has different training needs to a senior accountant who conducts CDD. AUSTRAC expects training to be tailored and regularly refreshed — not a one-time generic online module completed at onboarding and never revisited.
For sole practitioners, you must still document your own training. Attending industry CPD sessions on AML/CTF, completing AUSTRAC's online training, or engaging an external compliance adviser all count — as long as you record it.
Most AML/CTF failures in professional service firms are not deliberate — they are failures of awareness. Staff who don't know what a suspicious transaction looks like can't report it. Staff who don't understand the CDD process will cut corners under time pressure. Training is what converts a written compliance program into actual behaviour.
AUSTRAC's risk-based approach acknowledges that no compliance program eliminates all ML/TF risk. But a well-trained team is your most important control. It is the one that operates in every client interaction, without needing a system or a checklist.
Training must keep pace with regulatory change. As the AML/CTF framework evolves — new AUSTRAC guidance, new designated services, changes to your program — your training must be updated to reflect those changes. A training record from 2026 that has never been refreshed will not satisfy an auditor in 2028.
Inadequate training is one of the most common findings in AUSTRAC compliance audits. It is also one of the most difficult to remediate quickly — you cannot retroactively train staff on things that already happened.
If a staff member files an incorrect SMR, or fails to identify a suspicious client, and you cannot demonstrate they received appropriate training, AUSTRAC will hold the practice responsible for the systems failure — not just the individual. Penalties for systemic training failures can be substantial, particularly where the breach involves a pattern of missed red flags.
There is also a professional indemnity angle. If your practice is later implicated in a money laundering matter, your insurer will want to see that your staff were trained to identify and escalate exactly the kind of activity that occurred. Missing training records are a significant liability.
SimpleAML tracks the record-keeping side of training — it does not provide the training itself. For AML/CTF training content, AUSTRAC provides free online training modules, and industry bodies including CPA Australia and CA ANZ publish guidance materials. SimpleAML also maintains a list of approved training providers — view approved AML/CTF training providers →. Your training records in SimpleAML can reference whichever provider and content you use.
Document your AML/CTF training completions and stay ahead of renewals. No account needed.
Open SimpleAML Free →