Designate an AML/CTF Compliance Officer

Your practice must appoint an AML/CTF Compliance Officer by 1 July 2026.

The Compliance Officer must be an individual who:

• Is employed or engaged by the legal practice at a management level
• Has sufficient authority, independence and access to resources and information to perform their duties effectively
• Is a resident of Australia (if your practice provides designated services at or through a permanent establishment in Australia)
• Is a fit and proper person, and
• Cannot be outsourced – the officer must be appointed from within your practice

When making this appointment, your practice must also consider the factors listed in Rule 5-14, including whether the individual:

• Has the competence, skills and knowledge to perform their duties effectively
• Is of good character, honesty and integrity
• Has been convicted of a serious offence
• Has been subject to civil, criminal, regulatory or disciplinary proceedings
• Is an undischarged bankrupt
• Has executed a personal insolvency agreement
• Has any conflict of interest that could materially affect their ability to perform their duties

Role of the AML/CTF Compliance Officer

The Compliance Officer is responsible for overseeing your practice’s adherence to the AML/CTF regime.

Their key duties include:

• Managing the practice’s day-to-day compliance with AML/CTF obligations
• Ensuring your AML/CTF Program is current, effective, and consistently followed
• Monitoring transactions for suspicious activity
• Identifying and addressing high-risk or potentially suspicious matters
• Communicating and reporting to AUSTRAC (including Suspicious Matter Reports and Threshold Transaction Reports)
• Coordinating and overseeing staff training

Training Your Staff

Practitioners must ensure all staff receive appropriate AML/CTF training, covering both the requirements of the regime and your practice’s internal processes.

Training should include:

• Understanding and managing ML/TF risks
• Identifying red flags and suspicious activity
• Reporting obligations and escalation processes

Training must be provided:

• Initially, when staff commence employment or engagement, and
• Ongoing, to ensure awareness remains current and effective

You must also conduct personal due diligence on staff before and during their employment or engagement.

All training activities must be documented within your AML/CTF Policies. The Compliance Officer is responsible for overseeing staff training and ensuring it remains up to date and effective.