Employee training: AML/CTF risk awareness training program
All reporting entities must provide money laundering/terrorism financing risk awareness training for employees. This is to help them understand:
- the type of money laundering/terrorism financing risk your business or organisation might face
- your business or organisation’s obligations under Australia’s AML/CTF law and how you meet them.
This is compulsory. The training program must be documented in Part A of your AML/CTF program and help you make sure your business or organisation isn’t used to support criminal activity.
You should regularly review your training program to make sure it covers changes to the level of ML/TF risk your business or organisation faces.
Your AML/CTF risk awareness training program
Your risk awareness training program must be a written plan that shows how employees are instructed about the following:
- your obligations under Australia’s AML/CTF law
- the consequences of not complying with AML/CTF legislation
- the type of money laundering (ML) or terrorism financing (TF) your business or organisation might face and the consequences of this risk
- how you meet your obligations, including your processes and procedures to identify, manage and mitigate this risk.
Your written program must detail how you run your training program for employees according to your level of money laundering/terrorism financing risk. It might also include:
- which employees need training, such as new employees, employees being promoted or transferred, senior managers, consultants and new directors
- what the training intends to achieve.
Who needs training
You should give your employees regular AML/CTF risk awareness training. You may also wish to consider providing AML/CTF risk awareness training to board members, senior managers, directors and consultants who are involved in providing designated services to your customers.
The content and frequency of the training will depend on people’s role in the organisation and the ML/TF risk your business or organisation may face.
Types of training
The types of training you provide for employees is your decision and depends on your money laundering/terrorism financing risks, but you should specify the details in your plan. Options include:
- online training courses
- in-house or external training with an instructor
- on-the-job training, especially if the risks are specific to a certain role
- induction training for new employees and existing employees who take on new roles or positions
- regular communication to employees via email, notices or bulletins, about any changes or updates to your ML/TF risk systems, controls and procedures.
The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.