Teach the work each person must do
Role-based AML training connects a person’s tasks to the risks and obligations they must manage.
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: Australian Government, Federal Register of Legislation: 26F(2) and (4)(e); Australian Government, 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: Australian Government, Federal Register of Legislation: 5-9; Australian Government, 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.
Source: Australian Government, Federal Register of Legislation: 5-9 and 5-10.
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: Australian Government, 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
Illustrative training method. Attendance alone does not show ability, and this exercise does not replace independent evaluation.
Follow the process from top to bottom.