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What is an AML/CTF Compliance Officer and how do I appoint one?

:::note Key takeaway Every agency covered by Tranche 2 must appoint a Compliance Officer at senior management level. For most small agencies, this will be the principal. You must notify AUSTRAC of your Compliance Officer by 29 July 2026. AML Simple stores the appointment details in your program record. :::

What is the Compliance Officer role?

The AML/CTF Compliance Officer is the person responsible for overseeing your agency’s compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

Their job is to:

  • Oversee the implementation of the AML/CTF program
  • Keep the program up to date as the business and regulations change
  • Ensure staff receive appropriate AML/CTF training
  • Review and approve Suspicious Matter Reports before filing
  • Act as the internal point of contact for compliance questions
  • Liaise with AUSTRAC if required

The role is ongoing — it’s not a one-off appointment you make and forget about.

Who can be the Compliance Officer?

The Compliance Officer must be:

  • At senior management level — they need the authority to make decisions and direct staff on compliance matters
  • A suitable person — appropriate for the role based on their experience, knowledge, and character
  • Employed by or otherwise responsible to the agency (you can’t outsource this to an external party without appropriate arrangements)

For most small agencies (sole principal or a few staff), the agency principal will be the natural choice. If you have a senior staff member with relevant experience, they could also take on the role.

There’s no formal licensing or certification required by AUSTRAC for the Compliance Officer role — but the person should have or develop a working understanding of AML/CTF obligations. AML Simple includes a training module to help.

Do I need to tell AUSTRAC?

Yes. You must notify AUSTRAC of your Compliance Officer’s details by 29 July 2026 (this is the transitional deadline for newly regulated entities). You do this through AUSTRAC Connect, the online portal.

If your Compliance Officer changes, you must update AUSTRAC within 14 days.

How to record the appointment in AML Simple

  1. Open the Program section in the left navigation
  2. In the program wizard, go to the Compliance Officer step
  3. Enter the CO’s name, title, and contact details
  4. Save

AML Simple stores this information as part of your AML/CTF program record. When you generate your program PDF, the CO’s details are included in the document.

You’ll also see the CO listed on your dashboard — along with a reminder if the AUSTRAC notification deadline is approaching.

Can the Compliance Officer role change hands?

Yes. If the person changes (e.g. a new principal takes over or a senior staff member is promoted), update the record in AML Simple and notify AUSTRAC within 14 days of the change. The 14-day notification requirement applies to any change in enrolment details.

Training for the Compliance Officer

The Compliance Officer should have a solid understanding of:

  • What AML/CTF obligations apply to your agency
  • How to identify suspicious activity
  • How and when to file a Suspicious Matter Report
  • What CDD requires
  • Record keeping obligations

AML Simple’s staff training module includes content covering all of these areas. Professional and Agency plan subscribers can track completion across the whole team.

This article describes what the Compliance Officer role involves at a general level. Your specific obligations — including what “fit and proper” means for your agency — may depend on your circumstances. AML Simple is a workflow tool, not a source of legal or compliance advice. If you’re unsure whether a particular person is appropriate for the role, consult a qualified AML professional.

Have a specific compliance question? Book a 1:1 with an AML expert for personalised guidance from a qualified compliance professional.