Teach the work each person must do
AML training teaches a person how to perform their AML/CTF tasks, recognise relevant risks and refer concerns to the correct reviewer. Role-based training connects these skills to the work the person actually does.
For services through an Australian permanent establishment, AML/CTF policies must provide initial and ongoing training for people with relevant functions.
The training must be readily understandable to that person.
Sources: Federal Register of Legislation: 26F(2) and (4)(e); Federal Register of Legislation: 5-9.
Match training to responsibilities
The training must suit the person’s particular function, relevant money laundering, terrorism financing and proliferation financing risks, and responsibilities under the AML/CTF policies.
Initial training applies on employment or engagement. Ongoing training is also required. Rule 5-9 does not set one annual course for every role.
The business must comply with its AML/CTF policies. Its own training requirements therefore matter as well as the minimum requirements in the Rules.
Sources: Federal Register of Legislation: 5-9; Federal Register of Legislation: 26G.
Use work tasks to plan training
A business can identify the decisions each role makes, the evidence it uses and the matters it must refer for action.
For example, customer-facing staff may need practice with incomplete identity evidence. A manager may need practice with an internal escalation and the required decision record.
These are possible training methods. The law does not prescribe these particular exercises. Training does not replace the independent evaluation of the AML/CTF program.
Example training plan for a small practice
This example links a role to a topic, exercise, evidence and review. Adapt it to the actual work, risks and AML/CTF policies. The rows are suggested methods, not a prescribed course or review frequency.
| Role | Topic | Exercise | Evidence | Review |
|---|---|---|---|---|
| Intake staff | Identity and authority checks | Find the missing representative authority in a fictional file | Completed case and trainer feedback | Repeat the case after feedback and when the procedure changes |
| Fee earner or accountant | Changes in customer activity | Compare new payment instructions with the recorded purpose | Written explanation and internal referral | Examine the decision with a reviewer |
| AML/CTF compliance officer | Alert review and reporting decisions | Review a fictional alert and record separate decisions | Decision record and unresolved questions | Check the reasoning and follow-up |
| Practice principal | Oversight and failed controls | Decide who owns a missed review and its correction | Action owner, due date and result | Check the correction works and update training if needed |
Sources: Federal Register of Legislation: 5-9 and 5-10; Federal Register of Legislation: 5-8 and 5-9.
Invented example: learning from a missed step
In a fictional practice, two staff members omit an authority check in a training case. The trainer explains the missing step and provides another case.
The manager records the topic, participants and result as evidence of the work done. Attendance alone does not show that a person can perform the task.
The practice uses the result to plan further training and supervision. This is an illustrative method, not a prescribed assessment format.
Source: Federal Register of Legislation: 5-8 and 5-9.
- Practice task
Staff apply the procedure to a fictional case.
- Observed gap
The trainer explains the missed authority check.
- Further practice
Use another case and record the result and support needed.
Use a work task to identify further training
Invented example. Attendance alone does not show ability, and this exercise does not replace independent evaluation.
Follow the process from top to bottom.
Is one annual AML course enough?
Rule 5-9 requires initial and ongoing training. It does not set one annual course for every role. The training must suit the person’s function, risks and responsibilities. Follow the business’s AML/CTF policies when deciding what training is needed.
Sources: Federal Register of Legislation: 5-9; Federal Register of Legislation: 26G.
What evidence can show that staff learned the task?
In a suggested training record, keep the topic, participants, exercise result and feedback. Record any follow-up and whether the person can complete the task after that feedback. Attendance records show attendance; a practical exercise can show how the person applied the instruction. These are illustrative methods.
How can a small team train for internal escalation?
Use a fictional matter with an unexplained change in instructions. Ask staff to record the concern, supporting facts and person who should review it. Ask the reviewer to identify unresolved questions and the next action. Keep customer-facing communications separate from restricted reporting information. This is a suggested exercise, not a legal reporting decision.
Sources: Federal Register of Legislation: 5-9 and 5-10; Federal Register of Legislation: 5-8 and 5-9.