AML/CTF compliance officer (AMLCO) requirements
Every reporting entity must appoint an AML/CTF compliance officer (AMLCO). This page covers who is eligible, how to hire or appoint one, how to assess them, what the role involves, and what records you must keep.
Notification deadline: 29 July 2026
Notify AUSTRAC of your compliance officer by 29 July 2026, or 14 days after enrolling — whichever is later.
Appointment requirements
- Must be appointed within 28 days of providing designated services
- Must be notified to AUSTRAC within 14 days of appointment using the enrolment form on AUSTRAC Online
- Must be replaced, and AUSTRAC notified, if they leave or become ineligible
Eligibility requirements
- Employed or engaged by your business at management level
- A resident of Australia (if you provide designated services at or through a permanent establishment in Australia)
- A fit and proper person
What counts as management level?
Larger business
- Risk manager
- Operations manager
- General manager
Smaller business
- Business owner
- Director
- Person responsible for managing broader risks or operations
- Management level refers to the person's authority in the business — not their job title
- A person can be at management level without having direct reports
- The compliance officer does not need to be an employee
- If external, they must have the authority, resources and expertise to perform the role
- In a reporting group, one member's compliance officer may also serve another member if they meet eligibility requirements for each
Hiring or appointing an AMLCO
Most Tranche 2 businesses don't hire externally for this role — they appoint someone who already meets the eligibility requirements. Which route makes sense depends on your size and risk:
Promote someone internally
- Best for
- Most small-to-mid Tranche 2 businesses — a partner, owner, or manager who already has authority over operations
- Watch out for
- They still need protected time and real authority to do the role, not just a title added to an existing job
Hire a dedicated AMLCO
- Best for
- Larger businesses, or those with higher-risk customers, multiple entities, or prior AUSTRAC contact
- Watch out for
- A full-time hire is a significant fixed cost most small Tranche 2 entities don't need
Engage an external or fractional AMLCO
- Best for
- Smaller businesses that want dedicated expertise without a full-time salary
- Watch out for
- An external appointee must still have real authority, resources and expertise — and you must assess them as fit and proper like any other candidate
Whoever you appoint, notify AUSTRAC within 14 days and keep a record of the fit and proper assessment below.
Fit and proper person assessment
Before appointing the person, you must assess whether they are fit and proper. You must consider whether they:
- Have the competence, skills, knowledge, diligence, expertise and soundness of judgement to properly perform the role
- Have good character, honesty and integrity
- Have not been convicted of a serious offence
- Are not the subject of adverse findings by a regulatory body
- Have not been found to have engaged in serious misconduct by a regulatory body
- Are not bankrupt or have not signed a personal insolvency agreement
- Do not have a conflict of interest that creates a material risk they will not act properly in the role
Examples of conflicts of interest include where the proposed compliance officer:
- Has interests with an AML/CTF software company that may affect vendor selection
- Acts as AML/CTF compliance officer for multiple other businesses in a way that may affect impartiality
Role and responsibilities
- Implementing and maintaining your AML/CTF program
- Overseeing compliance across the business
- Acting as the primary contact point with AUSTRAC
- Overseeing and coordinating day-to-day AML/CTF compliance
- Advising the governing body and senior management on ML/TF risks
- Communicating with AUSTRAC on all AML/CTF matters
- Giving reports to the governing body at least once every 12 months on AML/CTF compliance
- Overseeing the effective operation of compliance with your AML/CTF policies
The compliance officer must have sufficient:
Records you must keep
AUSTRAC expects your records to show:
- The name of the person appointed
- The period during which they acted as AML/CTF compliance officer
- How they meet the eligibility requirements, including any reassessments
- What you considered in determining their eligibility (e.g. fit and proper assessment)
Frequently asked questions
What is an AML/CTF compliance officer (AMLCO)?
The AML/CTF compliance officer (AMLCO) is the person your business appoints to implement and oversee your AML/CTF program, act as the main point of contact with AUSTRAC, and report to your governing body on compliance and ML/TF risk at least once every 12 months. Every reporting entity must have one — it's a role, not necessarily a dedicated job title.
How do I hire an AML/CTF compliance officer (AMLCO)?
Most Tranche 2 businesses appoint someone already at management level — an owner, partner or manager — rather than hiring externally. Before appointing anyone, assess them against the eligibility requirements (management level, Australian residency, fit and proper) and document that assessment. Larger or higher-risk businesses sometimes hire a dedicated or fractional AMLCO instead; either way, notify AUSTRAC within 14 days of the appointment.
How do I know if my compliance officer meets the eligibility requirements?
They need to be at management level in your business (authority, not job title), ordinarily resident in Australia if you operate through a permanent establishment here, and assessed as a fit and proper person — considering competence, character, any regulatory findings against them, and conflicts of interest. You must document what you considered in reaching that assessment.
Does the AMLCO need to be a full-time or dedicated role?
No. For most small and mid-sized Tranche 2 businesses, the compliance officer holds the role alongside their existing responsibilities. What matters is that they have genuine authority, access to resources and information, and enough time to perform the role effectively — not that it's their sole job.
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AML/CTF program requirements
The compliance officer role sits within your broader AML/CTF program obligations.
View program requirements →Comparing compliance platforms?
What to look for in an AML/CTF compliance platform, and how the options compare on cost and effort.
Read the buyer's guide →Based on AUSTRAC guidance on AML/CTF compliance officer requirements. Not legal advice. Requirements may be updated — verify on the AUSTRAC website before making appointments or notifications. Last updated 18 July 2026.