This page defines the character standards expected of all our personnel, including our staff, secondees and contractors. These standards are minimum suitability requirements that all personnel must meet both before engagement and throughout their employment. 

On this page

• Assessing character
• Integrity, character traits, values and behaviours
• Personnel security assessment: pre-engagement screening
• Decision outcome
• Complaints
• Security clearance process
• Ongoing suitability
• Privacy management

AUSTRAC’s mission is to use financial intelligence and regulation to detect, disrupt and deter money laundering, terrorism financing and other serious crime.

To achieve our mission, we must operate in a trusted environment, supported by a strong security and integrity culture. This culture protects employees and critical operational, regulatory and intelligence information from external and insider threats.

To maintain our strong security and integrity culture all personnel must: 

• meet AUSTRAC’s integrity standards
• demonstrate their ongoing accountability and commitment to upholding those standards. 

These standards reflect the AUSTRAC CEO’s expectation that all personnel demonstrate the highest levels of integrity.

This applies equally to all personnel. It’s designed to determine an individual’s suitability to gain access to official information, which may include unaccompanied access to our premises and information. It is based on the agency’s unique security and risk environment, directed under the AUSTRAC Personnel Security Policy Framework. It’s in line with the mandatory requirements of the Australian Government’s Protective Security Policy Framework (PSPF). 

Assessing character

All personnel must demonstrate the highest standards of integrity and behave in a manner that reflects the Australian Public Service (APS) Values, AUSTRAC values, professional standards and integrity requirements. Adherence to these standards is essential to: 

• protect our people, data and assets
• uphold AUSTRAC’s reputation
• maintain Australian Government, stakeholder and general public trust in AUSTRAC to deliver our mission. 

AUSTRAC personnel must also obtain the relevant level of security clearance.

The PSPF mandates that all personnel working in and for Australian Government entities undergo pre-employment screening. Pre-employment screening provides a level of assurance that personnel are suitable to access Australian Government resources and is a primary control to mitigate an entity’s personnel security risks. 

We pre-screen all personnel in compliance with the PSPF and assess character based on a range of investigations, questionnaires and independent checks. We do this to determine a candidate’s ability to comply with the APS and AUSTRAC standards in an official and private capacity.

Information considered

Prior to engagement, all candidates must complete a personnel suitability assessment (PSA). This requires candidates to provide or complete:

• official secrecy and privacy statement acknowledgement
• AUSTRAC informed consent
• National Police Checking Service (NPCS) informed consent
• personnel suitability assessment questionnaire
• statutory declaration requirement
• identity documents requirement to confirm identify and eligibility to work for AUSTRAC.

We use the above information in addition to: 

• AUSTRAC information in accordance with Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)
• AUSTRAC information collected as an Australian Public Service agency
• publicly available information such as a candidate’s digital footprint.  

Assessment

The overall assessment of a candidate considers of a range of characteristics, traits, attributes, skills and abilities. 

When we assess a candidate’s character, it’s based on available information related to that person’s ability to comply with the professional standards of AUSTRAC and the APS in an official and private capacity. 

We use 2 primary processes to determine suitability for employment:

1. the AUSTRAC personnel suitability assessment
2. a security clearance process conducted by an authorised vetting agency (AVA).

Both processes provide information about an employee’s (whether prospective or current) integrity, character and associations, and hence suitability for AUSTRAC employment. 

We set out the processes and required integrity and character standards below.

Integrity, character traits, values and behaviours

Personnel should possess and demonstrate an appropriate level of integrity. In the security context, integrity is defined as a range of character traits that demonstrate a soundness of character and moral principle. Personnel should possess these traits to provide confidence in their ability to protect Australian Government information, resources and activities.

Character

We assess candidates in accordance with the character traits outlined in Protective Security Policy Framework Section 19 ‘Personnel Security Vetting Process’: 

• honesty
• trustworthiness
• maturity
• tolerance
• resilience
• loyalty.

Values

Personnel must uphold APS and AUSTRAC values and behave in accordance with the APS Code of Conduct at all times. Personnel are entrusted with access to people, data, systems and facilities so they have a high level of responsibility to demonstrate the highest standards of behaviour aligned to these values. 

APS values

The APS values articulate the parliament's expectations of public servants in terms of performance and standards of behaviour. This is set out in Section 10 of the Public Service Act 1999. The principles of good public administration are embodied in the APS values, which require that personnel are:

• impartial
• committed to service
• accountable
• respectful
• ethical
• stewards of the public service.

AUSTRAC values

AUSTRAC core values guide our culture and support us to achieve our mission. We expect all personnel to demonstrate these values in their conduct at all times:

• trusted
• inclusive
• collaborative
• impactful.

Relationships and associations

Our mission and dual functions as both Australia's AML/CTF regulator and financial intelligence unit means personnel have additional security obligations. In particular, obligations against external actors and their proxies who operate, or conduct activities, counter to Australian Government and AUSTRAC objectives. 

We expect all personnel to conduct their activities without bias, conflict of interest, external influence or direction. To identify, mitigate and manage these risks, we expect personnel to declare relationships or associations that are, or could be perceived as, unsuitable for AUSTRAC personnel. 

Declaring these actual or perceived relationships and associations provides accountability and transparency against conflicts of interest or external influence.

Personnel suitability assessment: pre-engagement screening

At the pre-engagement screening stage, we evaluate all proposed engagements through the personnel suitability assessment (PSA). Before any personnel can work with AUSTRAC, they must satisfactorily complete the PSA which assesses their suitability from an integrity and character perspective to work with, or for, AUSTRAC.

The purpose of the PSA is to provide a level of assurance against minimum requirements, examining traits and behaviours, values and relationships and associations.

The information provided during the PSA process, including responses to our follow-up queries, inform our assessment of suitability. We consider the ‘whole person’ when we assess whether an individual is suitable for engagement. The assessment also considers our unique operating environment and security risk factors. Any doubt concerning personnel suitability will be resolved in favour of AUSTRAC’s interest.

We assess each individual circumstance and the final determination of suitability rests with an AUSTRAC delegate. 

Minimum requirements

In line with PSPF mandatory requirements, AUSTRAC pre-employment screening requires candidates to meet minimum requirements relating to identity and citizenship eligibility. These establish confidence in a person’s identity, provide a level of assurance about the individual, and ensures their primary eligibility for engagement. These minimum requirements are included as a component of the AUSTRAC PSA, which makes passing the PSA an essential qualification.

Disclosure

Individuals must disclose full information relevant to the assessment process. This includes:

• their full criminal history (spent or otherwise)
• driving history and penalties
• pending court outcomes
• any other relevant issues that could influence the assessment of their character.

Personnel must also self-identify character traits and behaviours. This may include past behaviours that do not align with expected traits, but will allow personnel to demonstrate how they have responded, and what their current attitudes and approaches are. This is key to demonstrating traits of honesty and maturity.

We may require individuals to provide further information as the PSA process advances. In these instances it’s important to give full and complete details of the circumstances. This includes, where applicable, any reasons for non-disclosure or obfuscated, false or misleading information, in the first instance and at the earliest opportunity.

In circumstances where an individual has disclosed information, including but not limited to a previous conviction (spent or otherwise), the AUSTRAC delegate will have regard to the whole application. The delegate will also give due consideration to the following when assessing that person’s character:

• date of the conduct, offences or conviction
• age of the applicant at the time of the conduct or offences
• seriousness of conduct or offences
• frequency or repeated nature of the conduct or offences which indicates a pattern of behaviour
• applicant’s conduct and lifestyle since the conduct or offences
• role the applicant will perform in AUSTRAC.

At all times through the PSA process, individuals only need to provide information that they are reasonably aware of. They don’t need to clarify or confirm this information with any third parties.

If an applicant fails to disclose required information, or obfuscates or provides any false or misleading information, this may result in the PSA not proceeding and AUSTRAC assessing the individual as unsuitable for employment at AUSTRAC. 

Other disclosure required

Commonwealth Spent Convictions Scheme

AUSTRAC is exempt from provisions within the Commonwealth Spent Convictions Scheme (Crimes Act 1914 - Section 85ZZH). Applicants must therefore disclose all convictions, spent or otherwise, to AUSTRAC when seeking employment.

Declarable associations

Applicants must disclose any declarable associations, which include but are not limited to: 

• any person or group of people, including family members
• those living in the same residence
• any person whom the applicant suspects to have a criminal conviction or who may be considered of poor character and reputation. 

This can include any:

• person involved in a group or organisation known or suspected to be involved in unlawful or criminal activities
• known criminals and criminal entities
• individuals or entities who operate, or conduct activities, counter to Australian Government interests and the AUSTRAC mission.

The declaration of any declarable association in itself will not automatically exclude an employee from being assessed as suitable, as not all declarable associations are of concern. We require this information to determine the nature of the association, and any potential or perceived concerns that may require appropriate risk-mitigation controls post-engagement. The AUSTRAC delegate will assess each application on a case-by-case basis.

Identity check

Personnel must meet identity requirements that allow for a verification of their identity to at least Level 3 (High) of Assurance of the National Identity Proofing Guidelines. This mandatory requirement is to establish confidence in a person’s identity. Individuals cannot undertake these processes anonymously or using a pseudonym. An individual’s identity must be established to assess their suitability for employment at AUSTRAC.

Eligibility (citizenship) check

Personnel must meet minimum eligibility requirements, through providing proof of Australian citizenship. This mandatory requirement is to establish their eligibility to work for the Australian Government. Holding dual citizenship does not preclude engagement at AUSTRAC.

Digital footprint check

We will conduct a digital footprint check on all personnel. This includes conducting an open internet search, as well as identifying and reviewing publicly accessible social media. Personnel must provide sufficient personal information about themselves, including details of online aliases and accounts, to allow for this assessment.

Personnel must ensure that their online behaviour:

• is consistent with what the general public would reasonably expect of someone who holds a position of public trust
• adheres to the PSPF and the APS Values, Code of Conduct and Employment Principles
• observes the Australian Public Service Commission (APSC) resource Social Media: Guidance for Australian Public Service Employees and Agencies.

National Police Check

A national police check (NPC) will be undertaken as part of the PSA. An NPC involves processing an individual’s biographic details to determine if the name of that individual matches any others who may have previous criminal convictions.

Exclusion periods

Criminal, driving and other integrity-related matters may be considered among other checks. We will consider the prior history of all applicants holistically and on a case-by-case basis. 

Insufficient or incorrect information supplied by an applicant may result in the termination of an application, or an exclusion period being applied including permanent exclusion of employment or engagement with AUSTRAC.

The AUSTRAC delegate may use their discretion when deciding to apply an exclusion period to an application.

Serious offences

Applicants who have been convicted of serious offences, including but not limited to convictions resulting in imprisonment, may be considered for permanent exclusion from employment or engagement with AUSTRAC at the AUSTRAC delegate’s discretion. As AUSTRAC’s key partners are within law enforcement and the National Intelligence Community (NIC), personnel must display adherence with the laws of Australia and other countries.

Decision outcome

We will assess the information provided through the PSA and determine if the requirements for suitability for engagement have been met.

A determination of suitability for engagement at AUSTRAC is based on careful consideration of a whole person assessment, consistent with the agency’s unique operating environment and security risk factors.

Where assessed personnel receive a determination of suitability through the PSA process, they may be issued an offer of employment.

In cases where a determination of suitability is subject to risk mitigation conditions, the assessed personnel will be provided with details of the proposed risk controls which must be agreed to, prior to the determination being finalised.

The process to initiate an Australian Government security clearance through the relevant AVA will only occur upon satisfactory completion of the PSA.

If we assess an individual as unsuitable following the completion of the PSA, they will not be issued with an offer of employment.

All PSA determinations are final and will not be reviewed. 

Complaints

If you wish to submit a complaint about AUSTRAC, including application of the AUSTRAC Character Standards or a PSA finding, visit AUSTRAC’s website for more details and please email complaintsaboutaustrac@austrac.gov.au with details of your complaint and any relevant information.  

Security clearance process

After being assessed as suitable under the PSA, all AUSTRAC candidates must undergo a Commonwealth security clearance process. Personnel must obtain and maintain a valid security clearance at the required level for their position or engagement. An AVA administers the security clearance process independently of AUSTRAC. Personnel may need to submit duplicate information to AUSTRAC and the AVA due to the separate processes.

We must share information of security concern with relevant AVAs. This includes personal information as defined in section 6 of the Privacy Act 1988 (Cth) (Privacy Act). When we hold security concerns relating to an individual, we will share that relevant information with the AVA through the duration of AUSTRAC’s sponsorship of the security clearance. It is a condition of employment that employees must consent to sharing security information with the relevant AVA. 

Ongoing suitability

The PSPF mandates that AUSTRAC must assess the ongoing suitability of personnel throughout their employment. All personnel must continue to uphold the character standards we expect.

We have mandatory ongoing personnel security maintenance processes in place that facilitate identifying and assessing vulnerabilities that may impact an individual’s continued suitability to access official information and security classified resources.

We may evaluate the ongoing suitability of personnel through the application of a periodic PSA. A periodic assessment will evaluate whether personnel continue to meet AUSTRAC minimum personnel security requirements. This includes maintaining a satisfactory status on AUSTRAC character checks, including agency-specific ongoing suitability and security checks, and any relevant risk management program.

We may implement specific arrangements tailored to individual circumstances as necessary.

Failure to meet our ongoing suitability requirements may result in AUSTRAC reducing or withdrawing sponsorship of a personnel’s security clearance, which could result in termination of engagement with AUSTRAC.

Privacy management

We’re committed to protecting the privacy and personal information of our personnel and we adhere to the Australian Privacy Principles set out in the Privacy Act 1988.

We collect personal information to assess individual personnel security risk profiles and suitability to access Australian Government official resources. This includes sensitive personal information as defined by section 6 of the Privacy Act

Personal information, including sensitive information, may be collected from and disclosed to any entity or person listed in: 

• our privacy policy
• the Privacy Notice and Informed Consent Form we will provide to personnel at the pre-engagement stage. 

If an individual does not provide informed consent for this collection and handling of their personal information then assessment of their suitability for employment cannot proceed, precluding their ability to be employed by AUSTRAC.

Our privacy policy contains additional information regarding our privacy practices and contains information on how:

• an individual’s personal information is secured by AUSTRAC
• individuals can access and seek correction of personal information held by AUSTRAC
• individuals can make a complaint about a breach of the Australian Privacy Principles by AUSTRAC
• AUSTRAC will deal with a complaint.

The collection, use and disclosure of personal information in assessments is required and managed in accordance with the mandatory requirements of the PSPF. If an individual provides personal information not solicited by AUSTRAC that is not required for assessing their suitability for employment at AUSTRAC that information may need to be destroyed or deidentified.

Guidance on all privacy-related matters is available from the Privacy and Information Access Team: privacy@austrac.gov.au