Compliance officer role for a micro business

People search “austrac compliance officer” when a two-person firm has to name someone on the program and is not sure the title means a full-time job. Checked against the AUSTRAC compliance officer page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Whether a sole trader can be their own officer is a different question, on can a sole trader be their own compliance officer. Governance for the smallest businesses is also on AUSTRAC’s sole trader and micro-business page. The sector map is /tranche-2.

What the role is for

In a micro business the AUSTRAC compliance officer is the name on the governance page of the program. That person keeps the program current, sees that staff follow it, and is the internal point for a suspicious matter. They do not have to be a lawyer, and they do not have to stop doing the firm’s ordinary work. They do have to be able to tell the business to wait.

• Authority is the job. If the officer cannot pause a designated service until customer due diligence is finished, the title is only a name on a page.
• Oversight is not every keystroke. The officer makes sure the program is followed. Another person can collect the documents the program names.
• The appointment is written. Record who holds the role, from which date, and who covers leave. A verbal understanding in a two-person office is how the role goes missing.
• Enrolment stays with the business. The officer does not replace the enrolment. The business enrols. The officer runs the program the business approved.

Three hats, still one role description

A micro business often has the same person as senior manager and as compliance officer. That is allowed where AUSTRAC’s governance guidance for small businesses says so. It is not an excuse to skip the role. Write the two hats on separate lines so a later reader can see which decision was management and which was program oversight.

Where this page stops

This page is the micro-business role. It is not the sole-trader question and it is not a staff-training course. Training for people who are not specialists sits on AML training for non-specialist staff. How the program is written sits on the AML/CTF program for Tranche 2.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Appointing the officer is not a check. When the program then requires a customer to be verified, that verification is a separate client-pays check. Confirm the live amounts on FreeAML pricing. FreeAML does not appoint your compliance officer or approve the program.

Frequently Asked Questions