AML/CTF Training Built For Accounting Firms Facing Tranche 2 Obligations
Assign role-based modules, track completion, export certificates, and keep audit evidence in one place—without turning compliance into a full-time job.
General information only; not legal advice. Verify obligations with AUSTRAC .
Module preview:
Overview of the AML CTF Compliance Officer Obligations
PlayPause
Chapter 1 of 13
Overview of the AML CTF Compliance Officer Obligations
Course Library
AML/CTF training for accountants who need more than a basic checklist
Access 24 clear, practical modules designed to help accounting firms understand their Tranche 2 AML/CTF obligations, train staff consistently, and keep evidence of completion ready when needed.
1. Overview of the AML CTF Compliance Officer Obligations
AML/CTF
Self-paced
Video module
Chapters
01Overview of the AML CTF Compliance Officer Obligations
02The Role of the AML/CTF Compliance Officer
03Seniority & 'Fit and Proper' Requirements
04Core Responsibilities: Managing the AML/CTF Program
05Liaison with AUSTRAC & Regulatory Reporting
2. Overview of the Australian AML/CTF Regime
AML/CTF
Self-paced
Video module
Chapters
01Overview of the Australian AML/CTF Regime
02Introduction to Australia's AML/CTF Regime
03Evolution from Tranche 1 to Tranche 2
04Legislative Framework: The 2024 AML/CTF Reforms
05Who Is a Reporting Entity: Designated Services Overview
3. Overview of the Australian AML/CTF Penalty Framework
AML/CTF
Self-paced
Video module
Chapters
01Overview of the Australian AML/CTF Penalty Framework
02Introduction to the AML/CTF Penalty Framework
03Civil Penalty Framework: Maximum Penalties
04AUSTRAC's Enforcement Toolkit
05Criminal Sanctions under AML/CTF Law
4. Overview of AML/CTF Risk Assessment Requirements
AML/CTF
Self-paced
Video module
Chapters
01Overview of AML/CTF Risk Assessment Requirements
02Introduction to AML/CTF Risk Assessment
03Legal Requirements and the Risk-Based Approach
04The Four Pillars of Risk Identification
05Service (Product) Risk
5. Overview of AML/CTF Program Requirements
AML/CTF
Self-paced
Video module
Chapters
01Overview of AML/CTF Program Requirements
02Context and Legal Update on AML/CTF Requirement
03The "New" AML/CTF Program Framework
04Core Components: Customer Due Diligence and Transaction Monitoring
05Core Components: Reporting Systems and Staff Training
6. Staff Vetting & Employee Due Diligence
AML/CTF
Self-paced
Video module
Chapters
01Staff Vetting and Employee Due Diligence
02Introduction to Employee Due Diligence and Regulatory Context
03Understanding the Insider Threat in Professional Services
04Risks Posed by Unvetted Employees
05Regulatory Requirements for an Employee Due Diligence Program
7. AML/CTF Record-Keeping
AML/CTF
Self-paced
Video module
Chapters
01AML/CTF Record-Keeping Training
02Introduction to AML/CTF Record-Keeping
03The Golden Rule: The 7-Year Retention Requirement
04Customer Records: What Must You Keep?
05Transaction Records: What Must You Keep?
8. AML/CTF Staff Risk Awareness Training
AML/CTF
Self-paced
Video module
Chapters
01AML/CTF Staff Risk Awareness Training
02Mandatory Requirement for AML/CTF Risk Awareness Training
03Who Must Be Trained? Defining Relevant Staff
04Core Training Content for AML/CTF Compliance
05Training Frequency and Delivery
9. CDD for Individual Clients
AML/CTF
Self-paced
Video module
Chapters
01Customer Due Diligence for Individual Clients
02Introduction to Customer Due Diligence (CDD)
03Identity Pillars: Information You Must Collect
04Identity Pillars: Information You Must Verify
05Safe Harbour Minimum Standard: Primary Photographic ID
10. Corporate CDD & Beneficial Ownership
AML/CTF
Self-paced
Video module
Chapters
01Introduction to Corporate CDD
02Corporate CDD & Beneficial Ownership
03The Corporate "Shield" Concept
04Identifying the Company: Required Information
05Understanding Beneficial Ownership
11. Partnerships CDD and Control Structures
AML/CTF
Self-paced
Video module
Chapters
01Introduction to Partnership CDD & Control Structures
02Overview of Partnership Types in Australia
03General Partnership (GP) Details
04Limited Partnership (LP) Details
05Incorporated Limited Partnership (ILP) Details
12. Trust Customer Due Diligence and Transparency Standards
AML/CTF
Self-paced
Video module
Chapters
01Trust CDD & Transparency Standards
02Introduction to Trust Customer Due Diligence
03Understanding the Transparency Gap in Trusts
04Types of Trusts Covered by CDD Standards
05Key Information Required to Identify a Trust
13. Simplified Customer Due Diligence Training
AML/CTF
Self-paced
Video module
Chapters
01Simplified Customer Due Diligence (SCDD) Training Module
02Introduction to Simplified Customer Due Diligence
03Understanding the Risk-Based Approach (RBA)
04What is Simplified Customer Due Diligence?
05Differences Between Standard and Simplified CDD
14. Customer Risk Rating Overview
AML/CTF
Self-paced
Video module
Chapters
01Philosophy of Risk Rating
02The Four Risk Dimensions: Overview
03Customer Type Risk
04Jurisdictional (Geographic) Risk
05Service/Product Risk
15. Enhanced Due Diligence (EDD) Training
AML/CTF
Self-paced
Video module
Chapters
01Enhanced Due Diligence (EDD) Training
02Introduction to Enhanced Due Diligence (EDD)
03When to Apply Enhanced Due Diligence
04Politically Exposed Persons (PEP) Requirements
05Source of Funds (SoF) in Enhanced Due Diligence
16. High-Risk Screening: Country, PEPs, and Sanctions
02Introduction to Reporting Obligations under AML/CTF Act
03What are Suspicious Matter Reports (SMRs)?
04Triggers for Filing SMRs
05Reporting Timelines & The Tipping Off Offence
19. The Annual AML/CTF Compliance Report
AML/CTF
Self-paced
Video module
Chapters
01Purpose of the Annual Compliance Report (ACR)
02Legal Obligations and Significance of the ACR
03Reporting Timelines for Tranche 2 Entities
04Required Information for the ACR Submission
05Governance Requirements and Compliance Officers
20. Audit Requirements for AML/CTF Independent Review
AML/CTF
Self-paced
Video module
Chapters
01Introduction & Legal Mandate
02The Legal Purpose and Regulatory Expectation
03Independence Requirement: External vs Internal Review
04Audit Scope: Key Areas Reviewed
05CDD Testing and Reporting History
21. Red Flags for Lawyers, Accountants and Real Estate Firms
AML/CTF
Self-paced
Video module
Chapters
01Introduction to Red Flags and the Gatekeeper Risk
02Client Behaviour and Identity Red Flags
03Transactional and Substance Red Flags
04Privilege versus Reporting Obligations
05Red Flag Case Examples
22. Red Flags in Handling Client Funds
AML/CTF
Self-paced
Video module
Chapters
01Introduction to Handling Client Funds Safely
02The "Veneer of Legitimacy" Risk
03Operational & Transactional Red Flags
04The "Pass-Through" & Refund Fraud Scenario
05Client Profile & Behavioural Red Flags
23. Real Estate AML Red Flags
AML/CTF
Self-paced
Video module
Chapters
01The Appeal of Real Estate for Money Laundering
02Client & Entity Red Flags
03Transactional Red Flags
04Financial & Source of Funds Red Flags
05Escalation: What To Do?
24. Understanding Trade Based Money Laundering
AML/CTF
Self-paced
Video module
Chapters
01What is Trade-Based Money Laundering (TBML)?
02The Four Primary Techniques of TBML
03Under-Invoicing and Its Impact
04Multiple Invoicing and Ghost Shipping
05Why Professionals Are Targeted in TBML
Key Roles
Who Should Complete AML/CTF Training in an Accounting Firm
AML/CTF training should target roles most exposed to risk, not all staff. Key positions include:
Partners/Principals
Must understand firm-wide AML/CTF obligations and lead by example.
AML/CTF Compliance Officer
Manages reporting, reviews, and program maintenance.
Client Onboarding/Admin Staff
Handle KYC and identify identity or ownership issues.
Staff in High-Risk Areas
Accountants and support staff that are involved in managing client funds, forming corporate entities such as Companies, Partnerships etc. need to recognise sector-specific red flags.
Contractors/Outsourced Staff
Anyone performing AML/CTF tasks must be trained.
Targeted training ensures compliance is effective, risk-aware, and embedded in firm operations.
Training Coverage
What AML/CTF Training Must Cover
AML/CTF training must be practical and equip staff to identify and manage firm-specific risks. AUSTRAC expects coverage of four key areas:
When do AML/CTF obligations start for accountants in Australia?
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 has formally expanded the regulatory regime to include the accounting profession. While the legislation was passed in late 2024, AUSTRAC has confirmed a phased transition period. Full compliance obligations for "Tranche 2" entities, which include lawyers, accountants, and real estate agents, officially commence on 1 July 2026. By this date, accounting firms providing "designated services" must have their AML/CTF Program drafted, their Compliance Officer appointed, and all relevant staff trained. Early preparation is essential to ensure your internal processes are tested and compliant before the deadline.
What does AUSTRAC expect AML/CTF training to include?
AUSTRAC mandates that training must be "effective" and tailored to your firm’s specific risk profile. A compliant program should cover four critical areas: your firm’s legal obligations under the AML/CTF Act, the severe civil and criminal consequences of non-compliance (such as the "Tipping Off" offence), and the specific money laundering and terrorism financing (ML/TF) risks that accounting practices face. Crucially, training must also detail your firm’s internal procedures. This includes how to correctly identify and verify clients (CDD), how to recognise sector-specific "red flags," and the exact internal protocols for escalating suspicious matters to your Compliance Officer.
Who in an accounting firm needs AML/CTF training?
AML/CTF training is required for all "relevant roles" within your practice. AUSTRAC defines these as roles that assist in providing "designated services" or have the potential to identify or mitigate ML/TF risks. This encompasses partners and principals, the AML/CTF Compliance Officer, and client onboarding teams. Additionally, accountants and support staff working in high-risk areas, such as managing client funds and forming corporate entities etc. require specialised instruction. Even front-of-house staff should receive basic awareness training, as they are often the first point of contact and may be the first to witness suspicious behaviors, such as a client attempting to pay a large retainer in physical cash.
Do contractors need training?
Yes. AUSTRAC’s requirements extend to any individual you "engage" to perform a role relevant to your AML/CTF obligations. If your firm utilises contractors or outsourced service providers, particularly for functions like trust accounting, KYC/onboarding, or file management in regulated practice areas, they must be integrated into your Risk Awareness Training Program. It is the reporting entity's responsibility to ensure that anyone acting on their behalf understands the firm’s specific risk assessment and internal procedures. Ultimately, the firm remains legally liable for any compliance failures, regardless of whether the individual is a full-time employee or an external contractor.
How do we prove training was completed?
To satisfy AUSTRAC’s "show me" evidence standard, firms must maintain comprehensive records of all training activities for seven years. You must be able to prove that training was not just delivered, but also understood. This is best achieved by maintaining a centralized training register that logs the names of attendees, the dates of training, and the specific modules completed. Additionally, your records should include the training materials used, individual completion certificates, and assessment results (such as quiz scores). Having this digital "paper trail" ensures your firm is audit-ready and can demonstrate a robust culture of compliance during a regulatory inspection.
FAQs for Accountants
Everything you need to know to roll training out across the firm.