AML Compliance Guide
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Staff training for Bookkeeperss — 2026 AUSTRAC Guide

Bookkeeping practices that provide a designated service from 1 July 2026 must train staff who deal with customers or handle relevant transactions on your AML/CTF obligations. For bookkeepers, that usually means the people who onboard clients, verify identity, handle instructions involving client money, or spot unusual payment activity in payroll, accounts payable, trust-related work or international transfers. If you do not train the right people, document it, and repeat training when your program changes, you risk breaching the Act and AUSTRAC can take enforcement action, with civil penalties up to $33.5 million per contravention and criminal penalties for intentional contraventions.

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 a bookkeeping firm, staff training is not a one-off online module. Your training has to match the actual AML/CTF work each person does. A junior admin person who only books appointments needs general awareness training at onboarding. A team member who collects ID documents, sets up new clients in Xero or MYOB, processes payroll with unusual beneficiary changes, prepares payment runs, or handles international payment instructions needs role-specific training on customer due diligence, sanctions screening, suspicious matter escalation, record keeping and when a matter must go to the practice owner or AML/CTF compliance officer. Training must be understandable to the person receiving it and tailored to your business, not copied from a generic course without adaptation.

What your bookkeeping practice should do

  • Map which roles are AML/CTF-relevant: principal, practice manager, client onboarding staff, payroll officers, accounts payable staff, anyone handling client instructions involving transfers or entity set-up support.
  • Build training into your AML/CTF program and keep a written training plan linked to your ML/TF risk assessment and policies.
  • Give onboarding training before a person starts AML/CTF-related functions, then refresh it at the right intervals.
  • Train AML/CTF compliance officers and senior management every 6–12 months; customer-facing staff every 12 months; onboarding, transaction monitoring and enhanced CDD roles every 12 months; third-party vendors when onboarded and when the contract is renewed or changed; all other staff at onboarding for general awareness.
  • Update training as soon as practicable after law changes, program updates, new ML/TF risks, compliance review findings, breaches or AUSTRAC guidance.
  • Keep records showing who was trained, when, on what topics, how it was delivered, and whether they understood it.

Training records matter

AUSTRAC expects you to keep records reasonably necessary to show compliance with training obligations. For a bookkeeping practice, keep attendance logs, course content, version numbers, dates, quiz or assessment results, manager sign-off, and any remedial training given to staff who did not meet expectations.

Common mistakes for bookkeepers are very practical. Many assume tax return preparation or basic data entry automatically makes the whole firm regulated. It does not — only designated services trigger AML/CTF obligations. The opposite mistake is just as risky: assuming no training is needed because you are 'only a bookkeeper'. If your practice helps with higher-risk work such as managing client payment processes, handling instructions connected with company or trust structures, or arranging international transfers, the relevant staff need targeted training. Another common error is treating sanctions screening as a bank issue. If your staff onboard clients or act on instructions, they need to know how sanctions screening works and that dealing with a sanctioned person can be a strict-liability criminal offence.

Practical training topics for bookkeepers

  • How to identify when your service is actually a designated service and when it is not.
  • How to verify individuals, companies and trusts, including beneficial owners with 25%+ ownership or effective control.
  • What unusual activity looks like in bookkeeping work: sudden payroll account changes, round-dollar payments, unexplained cash handling, backdated supplier setups, or instructions to pay offshore without a clear business reason.
  • When physical cash of $10,000 or more triggers a TTR, and that EFTs, card payments and cheques do not.
  • How to escalate a suspicion internally without tipping off the client, and the 3 business day or 24 hour SMR deadlines.
  • How to store client ID, screening results, transaction records and training records for 7 years after the relationship ends.

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Frequently asked questions

Do I need to train every person in my bookkeeping business?
Not at the same depth. All other personnel should get general awareness training at onboarding, but anyone performing AML/CTF-related functions needs training matched to their role. In a bookkeeping practice, that usually includes the owner, onboarding staff, payroll and accounts staff handling relevant transactions, and anyone reviewing unusual client instructions.
Can I just buy an online AML course and use that for everyone?
You can use external training, including e-learning, but you cannot rely on generic content alone. You remain responsible for making sure it is tailored to bookkeeping work, your ML/TF risks, your AML/CTF policies, and each person’s role. Most practices will need to add internal examples, procedures and escalation steps.
What if I use offshore or outsourced staff for data entry or payroll support?
If they perform AML/CTF-relevant functions, they need appropriate training as well. Third-party vendors should be trained when onboarded and when the contract is renewed or changed. You should also keep records of what training they received and how you confirmed it was suitable for your business.
How much does staff training have to cost?
The law does not set a minimum spend. A small bookkeeping firm can use a mix of low-cost methods such as tailored induction checklists, short workshops, manager walkthroughs of real client scenarios, and external modules where useful. What matters is that the training is role-specific, understandable, repeated at the required times, and properly documented.
What do I do if a staff member still does not understand their AML/CTF duties after training?
Give targeted follow-up or remedial training, document what you did, and reassess their understanding through a test, observation or manager sign-off. If they still cannot meet AML/CTF expectations, you should escalate the issue and consider reassigning their AML/CTF functions or responsibilities. This is especially important for staff handling onboarding, payment instructions or suspicious matter escalation.

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