AML training for accountants: How to build an effective training program for Tranche 2

Accounting firms across Australia are preparing to meet AML/CTF obligations by 1 July 2026. That’s when Tranche 2 reforms kick in. A key element of that is AML training for accountants, which is a legal requirement under Section 84 of the AML/CTF Act.  

Most firms underestimate the training piece. It is not a box-tick at the end of compliance planning. It’s an important element that regulators will look at when something goes wrong, because every other obligation in an AML/CTF program depends on people’s understanding of what to do. 

This guide walks practice managers, partners, and compliance officers through how to build an AML training course for accountants that holds up to AUSTRAC scrutiny, covers every role in the firm, and is ready before 1 July. 

Key takeaways 

Why AML training for accountants matters 

Tranche 2 expands Australia's AML/CTF framework from 17,000 to 90,000 regulated entities. About 20,000 accounting firms will join banks and financial institutions as reporting entities, creating new obligations for their practice and teams. 

Solutions like EngageAML are designed explicitly to help firms meet these new obligations by combining engagement letter generation with a complete client due diligence process, ongoing monitoring, and reporting capabilities. 

Having said that, readiness among accounting firms remains low despite the looming deadline. A survey of more than 1,700 Australian accounting professionals found that only 6% felt on top of the incoming legislation, and 62% said they were unclear about the new rules. That gap, between obligation and understanding, is exactly what staff training is designed to close.  

The practical risks are serious. An untrained junior in an accounting firm who misses a red flag during onboarding may not immediately trigger a million-dollar penalty, but they can quietly facilitate a money-laundering chain AUSTRAC will trace back to your firm.  

This goes beyond reputational and financial damage. Accounting firms are now front-line monitors for money laundering and terrorism financing. Training turns a documented program into actual behaviour at the desk that can make material difference in the long-run. 

AML training requirements for accountants under the AML/CTF Act 

AUSTRAC's guidance is direct: your AML/CTF policies must ensure you can provide initial and ongoing training to personnel who perform AML/CTF functions, and that training must be tailored to each person's role and the risks they encounter. 

What the law requires: 

The phrase that catches most firms out is "personnel who perform AML/CTF functions". That isn't just your compliance officer. It includes anyone in client onboarding, anyone conducting Client Due Diligence, anyone handling AML/CTF-related records, and the partners making client acceptance decisions. For most practices, that is most of the firm. 

The other phrase that matters is "tailored". AUSTRAC's expectation is that a receptionist who never interacts with clients should not get the same training as a senior accountant conducting enhanced CDD on a high-risk trust client. Generic, one-size-fits-all training tells regulators you haven't thought about role-specific risk. 

Mandatory topics for AML/CTF training: 

Building your AML/CTF training program: Step-by-step guide 

Step 1: Assess training needs by role 

Map your firm by AML/CTF function before you build any content. Group staff into four tiers and define what each needs to know: 

Step 2: Develop training course 

Build modular content so you can train each role to the right depth without making everyone sit through everything. A practical module structure for an accounting practice covers eight areas: 

Modules should be built around realistic accounting scenarios, not banking examples. 

Step 3: Choose your delivery method 

The Act doesn't mandate a delivery method. What it does mandate is that AML training courses for accountants are accessible, understandable, and that you can prove staff engaged with it.  

The following formats work, and most practices end up blending them. 

Firms can also opt for a hybrid approach combining online modules with in-person Q&A sessions.   

Given the complexity of the subject, external training providers can be a real time-save for firms. Find a service provider that can deliver AML training courses for accountants with modules tailored to the accounting profession and tie the training to the day-to-day workflow for an accounting firm. 

Step 4: Create training materials 

Beyond module content, you need supporting materials staff use day to day. Some materials that would be useful include:  

Job aids are where training translates into behaviour. Print them, pin them up, embed them in your onboarding workflow. They should be easily accessible and part of common practice.  

Step 5: Schedule and deliver initial training 

Sequence matters. Train your compliance officer and partners first, then cascade to client-facing staff, then to support roles. Make sure you also communicate this clearly across your firm. 

Pre-1 July checklist: 

Step 6: Document everything 

AUSTRACT requires readily retrievable training logs that demonstrates reasonable steps taken to train staff. This is also a record of firms identifying potential gaps in their training program and how they fix it.  

Training logs for every individual should include: 

Keep certificates, attendance records, and training content versions on file. Records must be retained for at least seven years. 

Step 7: Implement Ongoing Training 

As mentioned above, training isn’t one-and-done. Firms must ensure AML/CTF training is ongoing. Consider the following pace:  

Step 8: Evaluate and improve 

Compliance officers, who are largely responsible for internal AML/CTF training, must keep apprised on the effectiveness of the firm’s program.  

They need to test whether training is working, not just whether it was delivered. They should: 

Five AML/CTF training mistakes (and how to avoid them) 

Conducting a one and done training session almost guarantees that team members will forget the procedure over time and remain unaware of regulatory changes. That’s why AML refresher training for accounting professionals is also a key element in a firm’s AML/CTF program. 

Fix: Schedule annual refreshers, send regular compliance reminders, and make sure to run updated training session when regulation or firm policy changes. 

Theoretical training without hands-on practice won’t serve your team well. Every training should  be designed to build the muscle of applying learnings in real life situations, which are often more nuanced and dynamic than a written test.  

Fix: Include case studies in every training and run role-play exercises for risk assessment, suspicious client interactions, and transaction monitoring.  

AUSTRAC can request training logs at any time. Firms must ensure that they have a complete audit training of internal AML/CTF training, or risk being fined for non-compliance.  

Fix: Maintain a training register for all staff including attendance records and assessment scored. Set reminders for refresher training.  

Compliance officers are key figures in a firm’s AML/CTF obligations, but if front line staff don’t understand their obligations, mistakes will happen early in the process and create a domino effect of non-compliance.  

Fix: Train all relevant staff with role-appropriate training. 

Banking scenarios do not resonate with accountants. When training doesn’t reflect their day-to-day accounting context, firm staff cannot be expected to fully understand how to apply it to their work.  

Fix: Customise training to accounting practice reality and avoid banking jargon. 

ChangeGPS AML/CTF Compliance Training  

Building your own program specific to your firm’s service list and client base could take months of internal work to do properly. With 1 July just around the corner, ChangeGPS's AML/CTF Compliance Training takes that off your plate and delivers AUSTRAC-aligned training that will get your firm confident and ready by the deadline. 

What's included: