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AML staff training: what the law requires and how to get it done before 1 July 2026

The AML/CTF Act 2006 requires all real estate staff to complete AML risk awareness training before they perform their first AML-relevant duty. Here is what training must cover, who needs it, and how to keep records.

By AML Simple Team

Staff must complete AML/CTF training before they perform their first AML-relevant duty after 1 July 2026. Not sometime in July. Before the first transaction.

That is the legal requirement under s 26F(4)(e) of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. Most agencies are focused on enrolment and program documents right now. Training is the obligation that tends to get pushed to last, and it is time-sensitive in a way that is easy to underestimate.

The fast path

If you are using AML Simple, your training obligations are built into the compliance workflow.

The program wizard identifies which staff perform AML-relevant duties and documents your training requirements as part of your AML/CTF program. Training records are tracked and stored in your compliance record (maintained for the required seven years per s 107 of the Act).

You still need to actually run the training. But AML Simple tells you exactly what to cover, and keeps the record straight.

Start your AML program. Takes around 15 minutes to generate your program document, including your training framework.

What the law actually says

The AML/CTF Act 2006 requires your agency's program to include policies and procedures for staff AML/CTF risk awareness training.

The specific rule (s 26F(4)(e), inserted by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024) requires that your program cover training for all staff who perform, or will perform, AML-relevant functions.

Three requirements follow from this:

  1. Training must be completed before a staff member starts performing AML-relevant duties
  2. Ongoing training must be provided, at a minimum annually
  3. Training records must be maintained

The first requirement is the one most agencies miss. "We'll run training in the week before July 1" is not compliant if your staff are processing transactions from July 1 and have not yet been trained. If you are enrolling with AUSTRAC and building your program now, staff training should be on the same timeline. Not a separate to-do item for later.

Who needs training

Any staff member who performs AML-relevant duties must be trained.

AML-relevant duties in a real estate agency include:

  • Conducting or overseeing customer due diligence (verifying client identity)
  • Assessing whether a suspicious matter report is needed
  • Handling transactions or negotiations involving property sales on behalf of clients
  • Managing or reviewing compliance records

In a five-person agency, that typically means everyone involved in sales, not just the compliance officer. Property management staff with no involvement in sales are generally not performing designated services and may not require training. Your risk assessment and program document should identify which roles are in scope.

What training must cover

AUSTRAC's Program Starter Kit and s 26F(4)(e) are aligned on content. Your training must cover:

  1. Your obligations under the AML/CTF Act 2006
  2. How to identify suspicious activity
  3. How to escalate concerns internally to the compliance officer
  4. Procedures for suspicious matter reports (SMRs) and threshold transaction reports (TTRs)
  5. Your agency's customer due diligence procedures
  6. Record-keeping requirements
  7. Consequences of non-compliance
  8. Real estate-specific risks and money laundering red flags

Point 8 is worth time. Real estate is identified by AUSTRAC as a high-risk sector specifically because of the size of transactions, the potential for layering through property purchases, and the involvement of complex ownership structures (family trusts, companies, foreign buyers). Staff should be able to recognise red flags (requests to pay deposits in cash, transactions involving a chain of entities, buyers seeking unusual settlement arrangements) and know what to do when they see them.

Generic compliance training that skips real estate-specific risk indicators will not satisfy this requirement.

Record-keeping

Training records must be maintained for seven years, consistent with the general record-keeping obligation under s 107 of the Act.

A basic training record should capture:

  • The name of each staff member trained
  • The date training was completed
  • The topics covered
  • Who delivered the training

This does not need to be a formal certification system. A sign-off sheet or a structured digital record is sufficient, as long as it can be produced if AUSTRAC requests it. The key is that you can demonstrate that training happened, when it happened, and what it covered.

Ongoing training

Training is not a one-off event. The Act requires ongoing training, at a minimum annually.

As obligations evolve (new AUSTRAC guidance, changes to CDD procedures, updates to your risk assessment), your training content should be updated to match. New staff must be trained before they start performing AML-relevant duties, regardless of when they join.

Your Annual Compliance Report (first period: 1 July to 31 December 2026, due 31 March 2027) will require you to report on training conducted during the period. If you have not run training by 31 December 2026, that is a gap in your report.

What counts as training

There is no prescribed format. AUSTRAC does not require a certified training provider or a specific course.

A structured internal session (the compliance officer walking staff through the 8 content areas, with a record of attendance and topics covered) satisfies the requirement. A short written guide followed by a Q&A works too. What matters is that staff have been exposed to the content, can recognise their obligations, and that you have documented it.

If you want to use a third-party training provider, that is an option. But it is not required, and for most small agencies it adds cost and complexity that is not necessary.

What to do now

If your agency's AML/CTF program is still being built, include training on the same timeline.

Check which staff perform AML-relevant duties. Schedule training before 1 July 2026. If you are enrolling close to that date, schedule it before your agency processes its first post-1-July transaction. Document what was covered and who attended. Set a calendar reminder for annual refresher training.

AML Simple's program wizard walks you through each of these steps, including identifying which staff need training, what your training content should cover, and how to keep records consistently. It is a compliance workflow tool, not a training course. The structured content and record-keeping are in the app; running the actual training session is your job.

Get started free

This post is general educational information about AML/CTF obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. It is not legal advice. If you have questions about your agency's specific obligations, consider speaking with a qualified AML/CTF compliance professional.

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