The responsibilities of an AML/CTF Compliance Officer are defined under Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 and its associated Rules and guides (the regime).

Your compliance officer is one of three defined roles in your AML/CTF governance structure which are a governing body, senior manager and compliance officer. These roles may be held by different individuals, or, in a smaller practice, one or more roles may be held by the same individual.

Under the regime, you must appoint an eligible individual to be your compliance officer who will be responsible for the oversight of, and compliance to, your AML/CTF program. For detailed guidance refer to Step 1: Establish your governance framework (Reform) in AUSTRAC’s guidance materials, specifically, AML/CTF compliance office (Reform).

Following is an overview of the process to appoint, and the role of, your AML/CTF Compliance Officer (CO).

Appointment

• You must appoint you CO within 28 days of providing designated services
• You must advise AUSTRAC of the appointment within 14 days using a specific online form (this will be available from 31 March, 2026)
• You must keep a record of your appointment which includes their name and how you determine their suitability.

Section 26J of the AML/CTF Act: Requires reporting entities to designate an AML/CTF Compliance Officer

Eligibility Requirements

To be appointed as an AML/CTF Compliance Officer, an individual must:

• Be at a management level within the organisation. For smaller practices, this may be the a partner in the firm, a director of the company or the owner of the business.
• Be a resident of Australia (if services are provided in Australia).
• Be a “fit and proper” person
• The CO does not need to be an AML/CTF expert on appointment though have the general skills to learn about, and execute the functions of the role

Section 5-14 of the AML/CTF Rules: Specifies criteria for assessing whether an individual is fit and proper.

Core Responsibilities

1. Oversight and Coordination of AML/CTF Compliance

• Coordinate and oversee the implementation and operation of your AML/CTF program.
• Ensure the practice complies with the AML/CTF regime and your AML/CTF Program.
• Communicate with AUSTRAC on behalf of your organisation, such as lodging suspicious matter reports.

Section 26L of the AML/CTF Act: Sets out the AML/CTF compliance officer’s functions.

2. Report to the Governing Body

This does not apply if the governing body is an individual or the same individual as the compliance officer.

• Provde regular (at least annually) reports to the governing body on compliance with, and effectiveness of, your AML/CTF program.
• Provide updates to risk assessments and any significant compliance issues as they occur.

Section 57 of the AML/CTF Rules: Requires the AML/CTF Compliance officer to report to the governing body.

Other Responsibilities

Other compliance activities that may be undertaken by your compliance officer include:

1. Suspicious Matter Reporting (SMRs)

• Oversee timely identification and reporting of suspicious matters to AUSTRAC.
• Ensure internal processes support prompt decision-making and compliance with reporting deadlines (e.g., 24 hours for terrorism financing suspicions).

Section 41 of the AML/CTF Act: Sets obligations for reporting suspicious matters.

Section 5-12 of the AML/CTF Rules: Requires AML/CTF policies to ensure timely determination and reporting.

2. Safeguards Against Tipping Off

• Implement policies to prevent unauthorised disclosure of SMRs or related information.
• Ensure confidentiality and secure handling of sensitive information.

Section 123 of the AML/CTF Act: Prohibits disclosure of SMR-related information.

Section 5-13 of the AML/CTF Rules: Requires safeguards in AML/CTF policies to prevent tipping off.

3. Record-Keeping

• Ensure accurate and secure record-keeping of AML/CTF activities, including training, risk assessments, reports, and policy updates.

Section 26N and 26P of the AML/CTF Act: Requires documentation and senior manager approval of AML/CTF programs.

Section 5-15 of the AML/CTF Rules: Specifies documentation timelines (before service commencement and within 14 days of updates).