By My CPE Pty Ltd | March 2026
This is the third Blog in our series on the AML/CFT Regime, as training forms part of Personnel Due Diligence.
What: Providing effective anti-money laundering and counter-terrorism financing (AML/CTF) training is part of the Personnel Due Diligence obligation. This is a core compliance responsibility for all reporting entities, including those newly regulated under Tranche 2. For those who are flying solo, the whole AML/CFT obligation falls in their bag, and training is just one aspect of this.
Why: Reporting Entities must undertake personnel due diligence and provide training to anyone performing roles connected to their AML/CTF obligations. This applies to employees as well as contractors, consultants, volunteers, interns and personnel engaged through service providers. Relevant personnel include those in governance roles, individuals with responsibilities under the AML/CTF program, staff exposed to ML/TF risks, and anyone supporting AML/CTF compliance functions. To identify these roles, organisations should list all positions linked to AML/CTF obligations and map the associated responsibilities and training requirements.
How: A well-designed Training Plan ensures personnel understand their legal obligations and are equipped to identify and manage money laundering and terrorism financing (ML/TF) risks relevant to their role.
Below outlines what an AML training program should cover, when it should be delivered, and how to ensure it remains effective and compliant, in compliance with AUSTRAC’s specific guidance.
Understanding Your AML/CTF Training Obligations
Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and associated Rules, businesses must provide AML/CTF training to any personnel performing functions connected to their AML/CFT compliance obligations. This includes employees and contractors involved in activities such as customer due diligence, transaction monitoring, reporting, governance, or oversight.
Training must be:
- Provided at the commencement of employment or engagement
- Ongoing throughout the individual’s time in the role.
The objective is to ensure personnel have the knowledge and capability to apply your AML/CTF program effectively and manage ML/TF risks appropriately.
Embedding Training Within Your AML/CTF Policies
Your AML/CTF policies should clearly outline how initial and ongoing training will be delivered. Importantly, training must be tailored according to:
- The individual’s role and responsibilities
- The ML/TF risks associated with those responsibilities
- Their obligations under your internal AML/CTF program.
Policies should also describe how your organisation:
- Develops and maintains a training plan
- Updates training to reflect regulatory changes and emerging risks
- Tracks completion and refresher training requirements
- Assesses whether knowledge is retained and applied.
Maintaining a structured training register is strongly recommended to support compliance monitoring and demonstrate accountability.
Training and Risk Exposure
Evaluating an individual’s skills, knowledge, and expertise involves determining whether they possess and can demonstrate the capability to perform the responsibilities required within their role, including the following:
- AML/CTF awareness
- Understanding ML/TF risks
- Understanding of AML/CTF obligations
- Ability to interpret and apply the organisation’s AML/CTF policies effectively and compliantly.
It is important to recognise that not all roles carry the same level of AML/CTF risk exposure. While general awareness training may be appropriate for some personnel, others require more specialised instruction.
For example:
- Customer-facing staff should have an awareness of AML/CFT and understand suspicious indicators and internal escalation procedures.
- Personnel conducting personnel or customer due diligence require deeper knowledge of the overall AML program, risk assessment, source of funds verification and investigative processes.
- Compliance officers and senior managers must have a comprehensive understanding of AML/CFT, including governance obligations, risk frameworks and oversight responsibilities.
When to Deliver Training
Initial training should occur at onboarding and before the person begins performing AML/CTF-related functions. Your ML/TF risk assessment, business size and sector-specific exposure should guide the depth and frequency of training. Ongoing training should be delivered at intervals appropriate to the individual’s role and risk exposure.
Additional or updated training should be provided when:
- AML/CTF laws or regulatory expectations change
- New or emerging ML/TF risks are identified
- You identify gaps in a person’s AML/CTF capability that may pose a risk of ML/TF or non-compliance
- Internal reviews or audits reveal knowledge gaps
- Significant compliance breaches occur
- Personnel move into new or higher-risk roles.
High-risk or governance roles may require refresher training more frequently than general staff.
Methods of Delivery
Organisations have flexibility in how training is delivered, provided it is accessible and understandable to participants.
Common approaches include:
- Online learning and certification programs
- In-person workshops
- On-the-job mentoring and supervision
- Industry seminars and professional development sessions
- Internal communications, such as newsletters or compliance updates.
Blended learning approaches often deliver stronger reinforcement of key compliance obligations. For instance, combining an online course with an internally facilitated compliance session enables participants to build foundational knowledge independently and then consolidate their understanding through discussion, practical examples and organisation-specific application. While external e-learning resources can support your program, they should support tailored training specific to your organisation’s risks and procedures.
Reviewing and Monitoring Effectiveness
Training should not be treated as a one-off compliance activity. Ongoing monitoring ensures it remains relevant and effective.
Organisations can evaluate effectiveness through:
- Post-training assessments or testing
- Internal compliance reviews and incident analysis
- Employee feedback and surveys
- Performance management processes
- Reports from the AML/CTF compliance officer to the governing body.
Where gaps are identified, targeted or remedial training should be implemented promptly. In some cases, reassignment of AML/CTF responsibilities may be necessary if competency requirements are not met.
Record-keeping Requirements
Businesses must retain records sufficient to demonstrate compliance with training obligations.
Useful records may include:
- Training plans
- Names and roles of personnel trained
- Training dates and delivery format
- Topics covered, training providers, version of materials used
- Assessment outcomes and follow-up actions
- History of refresher or role-specific training.
Training Register Template
Maintaining a comprehensive training register supports oversight, ensures timely training, and enables clear evidence of compliance if requested by regulators. A Template is included below.
Final Considerations
A well-designed AML/CTF training framework is fundamental to building a strong compliance culture and reducing exposure to ML/TF risk. Training should be practical, tailored to specific roles and reviewed regularly to reflect legislative developments, operational changes and emerging threats.
Given the complexity of the regulatory landscape, organisations benefit from structured, high-quality education that aligns closely with their AML/CTF program and risk profile. Engaging in specialised AML/CTF courses and webinars, such as those offered through My CPE, enables personnel to develop current, applied knowledge while supporting ongoing professional development requirements.
Comprehensive and accessible training is not simply a compliance obligation — it is a strategic safeguard that protects your organisation, strengthens governance capability and contributes to the integrity of the broader financial system.
Training Register Template
Click on the link below to download your complimentary Training Register Template.