--- title: "AML Staff Training: What's Actually Required? | HeadStart Docs™" description: "Understanding the minimum training requirements for AML/CTF compliance under Tranche 2. What training is mandatory, who needs it and how to deliver it." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation." } }, { "@type": "Question", "name": "How is HeadStart Docs different from the free AUSTRAC Starter Kits?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools." } }, { "@type": "Question", "name": "What if the AML/CTF rules change after I purchase?", "acceptedAnswer": { "@type": "Answer", "text": "Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists." } }, { "@type": "Question", "name": "What happens after my 12-month AML portal access expires?", "acceptedAnswer": { "@type": "Answer", "text": "Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required." } }, { "@type": "Question", "name": "Is HeadStart Docs a law firm?", "acceptedAnswer": { "@type": "Answer", "text": "No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel." } }, { "@type": "Question", "name": "When does AML/CTF Tranche 2 commence in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 AML/CTF obligations commence on 1 July 2026. 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[Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) [Tranche 2 Resources](/tranche-2-resources)/ General FAQs # AML Staff Training Requirements: What's Actually Required Under Tranche 2? The legislation requires employee training but doesn't prescribe exactly how. Here's what you need to know about meeting the training obligation. Updated February 2025• 6 min read ## Key Point You must provide AML/CTF training to employees who handle designated services or related functions. The format, duration and provider are not mandated - what matters is that staff understand their obligations. ## Who Needs Training? Your AML/CTF program must include provisions for training employees. This applies to: - Anyone providing designated services to customers - Staff involved in customer due diligence - Staff handling transaction monitoring - The AML/CTF Compliance Officer - Anyone who might identify suspicious activity For sole practitioners with no staff, you still need to ensure you have adequate knowledge - this counts as training yourself. ## What Must Training Cover? ### Core Training Topics - Overview of obligations Understanding the AML/CTF Act and reporting entity duties - Your AML/CTF program Specific procedures and policies for your business - Customer due diligence How to identify and verify customers - Suspicious matter identification Red flags and how to escalate concerns - Record keeping What records to keep and for how long - Tipping off Understanding the prohibition on disclosing reports ## How Can Training Be Delivered? The legislation doesn't mandate a specific format. Acceptable methods include: - **In-house training** - delivered by the Compliance Officer or management - **External courses** - from training providers or industry associations - **Online learning** - self-paced modules or webinars - **Documentation review** - structured reading of program materials with assessment - **Combination approach** - mix of methods as appropriate ## What You DON'T Need Despite what some providers suggest, there is no requirement for: - External certification - Minimum course duration - AUSTRAC-approved training - Annual recertification (though regular updates are good practice) - Expensive third-party courses ## Documentation Requirements You should maintain records of training provided, including: - Who was trained - When training occurred - What topics were covered - Evidence of completion (sign-off, quiz results etc.) This doesn't need to be complex - a training register or signed acknowledgment forms are sufficient. ## Practical Approach for Small Businesses 1. **Use your AML/CTF program** as the primary training material 2. **Walk through the documentation** with staff 3. **Discuss real-world examples** relevant to your services 4. **Have staff sign acknowledgment** that they've read and understood the program 5. **Provide updates** when procedures change or new risks emerge ## Ongoing Training Initial training isn't enough. Your program should include provisions for: - Refresher training at appropriate intervals - Updates when procedures change - Training for new employees - Addressing gaps identified through monitoring or audits ### Training Materials Included HeadStart Docs™ digital products include training material components designed to help you meet the employee training obligation. [View Training Material](/products/training-material) [All Digital Products](/programs) **Disclaimer:** This article is general information only. It is not legal, financial or compliance advice. HeadStart Docs™ provides free compliance documents, not legal services. We do not guarantee the accuracy of information provided. Obligations may apply depending on your designated services. Always confirm your specific requirements with a qualified adviser. Need a lawyer to review your AML/CTF program? [HeadStart Counsel](https://headstartcounsel.com.au/get-started) offers fixed-fee tailoring from $1,800+GST. 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