AML Compliance Guide
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Staff training for Accountants — 2026 AUSTRAC Guide

If your accounting practice provides a designated service from 1 July 2026, you must train the staff who deal with those matters so they can follow your AML/CTF program, identify risk, and handle customer checks and reporting properly. This matters for accountants because AML/CTF does not usually attach to every accounting job — tax return preparation alone is generally not a designated service — so your team needs to know exactly when the rules do and do not apply. If you get training wrong, the practice can miss customer due diligence, sanctions screening or suspicious matter reporting duties, exposing the business to AUSTRAC enforcement, civil penalties of up to $33.5 million per contravention, and criminal penalties for intentional breaches.

Your AML/CTF obligations

  1. 1. AUSTRAC enrolment
  2. 2. Compliance officer
  3. 3. ML/TF risk assessment
  4. 4. AML/CTF program
  5. 5. Customer due diligence
  6. 6. Sanctions screening
  7. 7. Suspicious matter reporting
  8. 8. Record keeping (7 years)
  9. 9. Staff training

For an accounting firm, staff training is not just a one-off slideshow. You need documented training for everyone who handles designated services, customer onboarding, transaction instructions, trust or company structures, movement of client money, or suspicious matter escalation. The training must match the person’s role and your firm’s actual ML/TF risks. AUSTRAC expects training to be understandable and tailored, so the content for a partner approving high-risk clients should be different from the content for a junior administrator collecting ID documents.

What your practice needs to do

  • Map which services in your firm are designated services and which are not. For many accountants, tax compliance work alone will not trigger AML/CTF, but services involving company or trust structures, handling assets, or arranging transactions may do so.
  • Identify who needs role-specific training: principals, onboarding staff, managers reviewing complex files, payroll or finance staff handling client funds, and anyone who may spot suspicious activity.
  • Build training into your AML/CTF program by 31 December 2026, with content on customer due diligence, beneficial ownership, PEPs, sanctions screening, suspicious matter escalation, record keeping, and tipping off.
  • Set a refresh cycle. AUSTRAC guidance says AML/CTF compliance officers and senior management should be trained every 6–12 months, customer-facing personnel every 12 months, and onboarding or enhanced CDD personnel every 12 months.
  • Keep a training register showing who completed training, their role, dates, topics, delivery method, version of materials, and any assessment results or remedial follow-up.

Training must change when your practice changes

Update training as soon as practicable after changes to AML/CTF laws, changes to your AML/CTF program, new ML/TF risks, AUSTRAC guidance, internal review findings, or a compliance breach. If your firm starts offering higher-risk advisory work involving trusts, shelf companies, or cross-border structures, your old training will not be enough.

Common mistakes in accounting practices are predictable. One is training the whole office as if every matter is captured, which causes confusion and poor escalation. Another is the opposite: assuming AML/CTF only affects partners, when reception, practice managers and paraprofessional staff often collect client information or see unusual payment behaviour first. A third is relying on generic online modules only. AUSTRAC says e-learning can help, but it cannot be the sole answer because training must reflect your accounting firm’s services, risks, policies and staff responsibilities.

Practical tips for accountants

  • Use examples your team will recognise: unexplained changes to company ownership, requests to use complex trust structures without a commercial reason, client reluctance to disclose beneficial owners, or urgent cross-border payment instructions.
  • Train staff on the line between ordinary accounting work and designated services so they know when AML/CTF starts.
  • Include a short escalation pathway in every training session: who to tell, how quickly, and what not to say to the client to avoid tipping off.
  • Test understanding with file reviews, short quizzes, or manager sign-off, then give remedial training where gaps are found.
  • If you outsource training, check the provider can tailor it to accounting services and your own AML/CTF program. You remain responsible for the result.

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Frequently asked questions

Do I need to train the whole accounting firm, even if only one team handles designated services?
No. Role-specific training should focus on staff who perform AML/CTF-relevant functions. But AUSTRAC guidance supports general awareness training for other personnel at onboarding, which is sensible in an accounting practice because support staff may still spot red flags or handle records.
If my firm only prepares tax returns and BAS, do I still need AML/CTF training?
Tax return preparation alone is generally not a designated service for accountants. If that is genuinely all your practice does, AML/CTF obligations may not be triggered. You should still confirm your service lines carefully, because advisory or transactional work around entities, trusts or assets can change the position.
Can I just buy an online AML course for my staff and treat that as done?
Not by itself. AUSTRAC says e-learning modules can be used as part of training, but they cannot be relied on solely to meet your obligations because the training must be tailored to your staff member’s function, your risks, and your AML/CTF policies. Most accounting firms will need to add internal procedures, examples and escalation instructions.
How much will staff training cost a small accounting practice?
There is no government fee for the training obligation itself. Your cost will usually be staff time, preparation of tailored materials, possible external training support, and maintaining training records. For a small firm, the cheaper option is often a simple internal program built around your actual designated services rather than broad generic compliance content.
What records should I keep to prove staff training happened?
Keep training materials, schedules, attendance records, dates, staff names and roles, delivery method, content version, assessment results, and any remedial training or follow-up. A training register is the easiest way to show AUSTRAC who was trained, when they were trained, and whether they were competent to perform their AML/CTF functions.

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