AML Compliance Training: Key Steps for Financial Services

In 2023–24, AUSTRAC received more than 380,000 suspicious matter reports – a sharp increase from the previous year that reflects the rising complexity and scale of financial crime in Australia. Behind each report is a frontline employee who spotted something unusual, raised the alarm and helped protect their organisation from potential criminal exploitation.

In Australia, financial service providers are on the frontline in the fight against financial crime. From banks and superannuation funds to wealth managers and fintechs, these organisations are required to implement robust measures to detect and prevent money laundering and terrorism financing. But policies alone aren’t enough. Training your people is one of the most effective defences against anti money laundering (AML) risk.

AUSTRAC – the national financial intelligence agency – expects businesses to deliver AML compliance training that is clear, ongoing and aligned to their obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. For organisations navigating complex risk environments, AML training isn’t just a regulatory checkbox. It’s a critical investment in resilience, trust and long-term success.

Why AML training is essential for financial services

Legal and regulatory responsibilities

Financial service providers have a legal obligation to maintain an AML/CTF program, with training forming a core part of Part A of that program. This includes:

• Educating employees on their roles in preventing financial crime
• Ensuring all relevant staff understand and can apply your AML/CTF policies and procedures
• Keeping training up to date with changes in risk exposure or legislation

AUSTRAC’s guidance makes it clear that compliance training should be risk-based and proportionate to the size, complexity and exposure of your business. Training must be tailored, relevant and repeated regularly. It should also be extended to all staff who interact with customers, process transactions or are involved in compliance.

Failure to deliver this training can result in penalties, reputational damage and regulatory scrutiny. A 2020 AUSTRAC enforcement action highlighted a major bank’s failure to properly train staff, contributing to systemic reporting issues and a record-breaking financial penalty. This underscores the importance of ensuring training is not only delivered but done so effectively.

Training as a control mechanism

AML training doesn’t just inform – it mitigates. Staff who understand the risks are better equipped to:

• Identify red flags
• Ask the right questions during onboarding or transactional reviews
• Escalate issues appropriately and without delay

When embedded effectively, training enhances operational vigilance and supports a broader culture of compliance across your organisation. This is especially vital in industries experiencing rapid innovation or growth, such as fintech, where product complexity can obscure risks if employees aren’t kept up-to-date.

Key components of an AML training program

Understanding money laundering techniques

To be effective, training must go beyond surface-level explanations. Employees need to understand how money laundering occurs in practice. Common techniques include:

• Structuring or smurfing: breaking large transactions into smaller amounts
• Trade-based laundering: manipulating invoices or over/under-valuing goods
• Use of third parties or shell companies to obscure ownership
• Exploitation of digital assets or emerging financial technologies

These techniques evolve constantly, which means ongoing training is vital. Including anonymised case studies, real-life regulatory examples and industry-specific content can help contextualise the threat and make it relevant to your teams.

Recognising and reporting suspicious activity

One of the most important outcomes of AML training is that employees know how to identify and report suspicious matters.

Your training should cover:

• Typical red flags in customer behaviour or transaction activity
• How and when to file a Suspicious Matter Report (SMR)
• Internal escalation channels and protections for staff who raise concerns

Embedding scenario-based learning, gamified assessments and decision-tree exercises can build employee confidence and reinforce these reporting protocols, especially for staff in high-volume transaction environments like banking operations or customer service.

Steps to implement AML training

AML compliance training essentials checklist

✔️ Tailored training aligned with role-specific risks
✔️ Ongoing refreshers and knowledge testing
✔️ LMS-enabled tracking and reporting
✔️ SMR reporting procedures clearly explained
✔️ Regular reviews to match evolving risk exposure

When you partner with Safetrac, you gain more than just access to high-quality AML training content. You gain a compliance partner that works closely with you to assess your risk landscape, tailor training to your people and deploy programs at scale – without disrupting operations. Whether you’re rolling out to a central office or remote teams across regions, Safetrac ensures your training is targeted, engaging and aligned with AUSTRAC’s expectations from day one.

Risk assessments and content customisation

Start with a risk assessment. What AML risks are most relevant to your business? What channels, services or client types increase your exposure?

Using this insight, customise your AML training to address the specific risks your employees are most likely to encounter. Tailoring content by role is also critical – for example, your onboarding team may need different guidance to your trading desk or compliance team.

Safetrac’s AML compliance training is fully customisable, allowing you to reflect your organisation’s risk profile, policies and procedures and even internal branding. This increases relevance and retention while helping meet AUSTRAC’s expectations for tailored training.

Choosing the right training platform

The effectiveness of AML training often comes down to accessibility and delivery. A robust learning management system (LMS) can:

• Ensure training is available on demand for geographically dispersed teams
• Track course completion and knowledge retention
• Trigger reminders for refresher training or regulatory updates
• Generate reporting for audits and board oversight

Safetrac’s ISO-certified compliance LMS is purpose-built for regulated organisations. It simplifies compliance, provides detailed visibility and integrates seamlessly with your internal frameworks. LMS features like automated onboarding pathways, team-specific dashboards and live training alerts are especially useful in larger financial institutions where teams may span multiple departments and jurisdictions. 

Common pitfalls to avoid

Even with the best intentions, AML training programs can fall short. Be aware of these common mistakes:

• Using generic, one-size-fits-all content that lacks relevance
• Failing to update content as regulations or risks evolve
• Neglecting refresher training after 12+ months
• Not tracking course completion or performance
• Overlooking audit-ready documentation of your training efforts

Ensuring ongoing compliance

Tracking, auditing and refresher courses

AML compliance is not a one-off exercise. AUSTRAC expects training to be ongoing and responsive to changes in business activities, risk levels and legislative requirements.

To stay compliant:

• Track who has completed training and when
• Schedule periodic refresher courses to keep knowledge current
• Review and update training materials as your risk profile evolves
• Conduct internal audits to assess the effectiveness of your training program

Additionally, maintain documented evidence of your training efforts, including versions of course content, attendance records and evaluation metrics. This not only assists in audits but provides valuable insight into whether the program is driving behaviour change.

Protect your business from financial crime

A strong AML training program does more than meet regulatory obligations – it empowers your team to recognise and respond to threats, fostering a culture of compliance and integrity.

Safetrac’s anti money laundering compliance training is designed specifically for financial services. With award-winning content, expert legal input and flexible delivery, our programs help your organisation meet AUSTRAC’s standards while reducing AML risk.

Let’s build your culture of compliance and protect your business from financial crime.

Whether you’re updating your AML/CTF program or starting from scratch, we’re here to help. Contact Safetrac to build training your people will actually use – and your auditors will trust.