AML Compliance Guide
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Staff training for Financial adviserss — 2026 AUSTRAC Guide

If your financial advice business provides a designated service from 1 July 2026, you must train staff who deal with clients, onboard entities, handle client money movements, or prepare reporting information so they can carry out your AML/CTF procedures properly. This applies because advisers often work with investment structures, trusts, companies, superannuation arrangements and cross-border funds movements that can be misused for money laundering or terrorism financing. If you do not train relevant staff, AUSTRAC can treat that as a breach of your AML/CTF obligations, 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 financial advice practice, staff training is not a one-off presentation and not just for advisers. Anyone involved in client onboarding, verifying identity documents, checking beneficial owners of companies and trusts, screening clients against DFAT and UN sanctions lists, identifying suspicious behaviour, handling cash-related issues, or preparing international transfer reporting needs training that matches their role. AUSTRAC expects initial training at the start of employment or engagement, ongoing training after that, and extra training before a person takes on new duties that expose them to different ML/TF risks.

What your practice should do

  • Identify which roles are AML/CTF-relevant in your advice business: advisers, paraplanners involved in onboarding, client service staff, operations staff, practice managers, your AML/CTF compliance officer and any senior manager approving high-risk clients.
  • Build training from your own ML/TF risk assessment and AML/CTF program. Cover the risks you actually face, such as complex ownership structures, self-managed super funds, trusts, politically exposed persons, offshore source of wealth and unusual investment funding arrangements.
  • Give initial training when a person starts, then ongoing refresher training. AUSTRAC guidance gives examples such as every 6–12 months for AML/CTF compliance officers and senior management, and every 12 months for customer-facing and onboarding staff.
  • Train staff on the practical steps they must follow: collecting and verifying ID, checking company and trust details, identifying beneficial owners at 25% or more or effective control, escalating suspicious matters, lodging reports on time and never tipping off a client.
  • Keep a training register showing who completed training, when, what was covered, how it was delivered, the version of the content and any assessment results or remedial follow-up.

What training must cover

Your training should include suspicious indicators relevant to advice businesses, escalation procedures and timelines, sanctions screening, threshold transaction reporting where any role is exposed to physical cash, record keeping, and each governance role’s responsibilities. AUSTRAC e-learning can help, but it cannot be the whole solution because your training must be tailored to your business, your services and each person’s duties.

A common mistake in financial advice firms is assuming AML/CTF training only matters if you personally move money. That is too narrow. Staff who recommend products, collect client information, set up accounts, receive explanations about source of funds, or spot unusual instructions may be the first to detect red flags. Another common mistake is using generic financial services training that says nothing about your own client types, referral channels, approved products, trust and company clients, or how your team should escalate a suspicious matter within the 3 business day SMR deadline or 24 hours for suspected terrorism financing.

Keep the training practical. Use real examples from advice work: a new client investing through a discretionary trust with an unclear controller, a retiree insisting on using a third party’s cash, a company client whose ownership does not match ASIC records, or a client asking for funds to be remitted overseas to an unrelated account. Short role-based modules work better than one long annual session. If someone misses training or fails an assessment, document the follow-up, provide remedial training and do not leave them performing AML/CTF functions unsupervised. Training should also be updated as soon as practicable when laws change, your AML/CTF program changes, new risks emerge, or AUSTRAC guidance highlights gaps.

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Frequently asked questions

Do all staff in my financial advice practice need AML/CTF training?
Not everyone needs the same depth of training, but every person with AML/CTF-relevant duties does need training matched to their role. In a typical advice practice that usually includes advisers, client services staff handling onboarding, operations staff involved in money movement instructions, the AML/CTF compliance officer and senior managers. Staff with no AML/CTF-relevant role may only need general awareness at onboarding.
Can I just use AUSTRAC’s online modules and count that as compliant training?
No. AUSTRAC says its e-learning can be used as part of training, but it cannot be relied on solely to meet your obligation. You still need to tailor the training to your advice business, your client risks, your AML/CTF policies and each person’s responsibilities.
We outsource paraplanning and some admin functions. Do those people need training too?
Yes, if they perform functions that expose them to your AML/CTF risks or they carry out AML/CTF tasks for your business. AUSTRAC guidance specifically contemplates training third-party vendors when they are onboarded and when the contract is renewed or changed. You remain responsible for making sure the training is appropriate and understandable.
How often should we retrain advisers and client service staff?
Training must be ongoing, and the frequency depends on the person’s role and the risks they handle. AUSTRAC gives examples of every 12 months for customer-facing and onboarding staff, and every 6–12 months for AML/CTF compliance officers and senior management. You should also retrain sooner when your program changes, new risks appear, or a breach shows your training was not effective.
What records do I need to keep to prove our training happened?
Keep records reasonably necessary to demonstrate compliance, such as attendance logs, training schedules, materials used, delivery method, assessment results and remedial action for non-attendance or failed understanding. For a financial advice practice, it is also sensible to record which roles were covered, what scenarios were used and which version of your AML/CTF program the training reflected. These records should fit into your 7-year AML/CTF record-keeping framework.

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