AML training for staff who are not compliance specialists

AML training is the firm’s obligation, not a certificate you buy. AUSTRAC’s AML/CTF training guidance says you train personnel who perform functions relevant to your obligations, at the start and on an ongoing basis, in a way that fits the role. You can use an outside provider. You stay responsible for whether the training fits your business. This page is general information, not legal advice. Who is in scope across the reforms is on /tranche-2.

Who counts as “not a specialist”

AUSTRAC’s page on identifying personnel roles is wider than the compliance officer. It includes people in governance, people with duties under the program, and people in roles exposed to money-laundering risk. In a small firm that is often the receptionist who opens the email, the assistant who collects identity, the salesperson who meets the buyer, and the junior who handles the file. A person with no customer contact and no AML duty may sit outside. Write that down. Do not train nobody because nobody has “compliance” in their title.

The three jobs: recognise, escalate, attest

1. Recognise. Customer-facing people need the indicators your program already lists: a story that does not match the service, pressure to skip identity, a structure nobody can explain, a cash pattern that looks split. They do not need a casebook of typologies.
2. Escalate. The training should name the person and the path. “Tell the compliance officer the same day, in writing, and do not tip the customer off that a report might follow.” AUSTRAC’s tipping-off guidance is the rule. The specialist decides whether a suspicious matter report is required. The non-specialist’s job is to pass the fact up intact.
3. Attest. AUSTRAC expects a register of who completed training and when the next round is due. An attestation is that record: the person, the module, the date, and that they know the escalate path. It is not a qualification.

What not to buy

A paid certificate with your logo on it does not discharge the obligation. AUSTRAC says outsourced training still has to be tailored, understandable, and checked for whether people can apply it. A generic course that never mentions your escalate path is awareness, not your program. Role depth still differs: onboarding staff need the identity and beneficial-owner steps; someone who might see a suspicious matter needs the escalate clock; the compliance officer needs the governance material. One slideshow for the whole firm is a start only if you then add the role piece.

The existing notes on this site stay in place. Free AML training and free AML training in Australia describe the modules. This page is who they are for when the person is not a compliance specialist, and what “done” means.

How the free suite is used

The FreeAML firm suite is A$0, including the training modules at Trainings. A staff member works through a module and the quiz. The completion record is the firm’s sign-off to file in its own training register. The certificate confirms the module was completed. It is not an accreditation, and FreeAML is not a certificate mill. The firm decides who must attend, how often, and how the register is retained. AUSTRAC’s guidance is the standard for that register. The product does not replace it.

Verification of customers is separate and client-pays. Prices are on FreeAML pricing. Training the receptionist does not, by itself, verify the customer. When the program says a check is required, send the request by email so there is a written trail.

Frequently Asked Questions