AML training: The Rules tell you ‘what’ but the ‘why’ makes it stick

Under the AML/CTF Act and Rules, firms are required to provide AML/CTF training to relevant staff at the start of their role, update that training on an ongoing basis, and keep records to demonstrate compliance. That’s the what.

But the legislation doesn’t explain why training matters. And unless people understand the why, AML training risks becoming a tick-box exercise that is quickly forgotten.

We sat down with Emma Senior, Founder of Alpha AML Training, to discuss what makes AML training effective and how firms preparing for Tranche 2 reforms can get this right from the start. We also asked several AML Compliance Officers (AMLCOs) / Money Laundering Reporting Officers (MLROs) from New Zealand and the UK for their lived experiences. 

Don’t forget the "why"

So Emma, you’ve worked with hundreds of AMLCOS over the years, what’s the main thing the best ones do to get great results from their AML training?

“The legislation makes it clear that staff training must be part of your AML/CTF program. One of the biggest mistakes I see is a lack of staff engagement and thinking that simply handing staff a copy of the program, or distributing AML articles or documents, will do. It’s no wonder AML training is often described as ‘dry’! 

Instead, many of the successful AMLCOs I’ve worked with go beyond the ‘what’ of the law. Of course they focus on the ‘what’ but importantly, they also include the ‘why’ and how these rules not only protect their firm and their clients, but also help to disrupt and reduce the serious crimes that generate illicit funds in the first place.”

Michelle Garlick, MLRO, Weightmans, echoes this:

“Explain to [staff] the ‘why’ and what it means in practice rather than stating just what the regulations say. It’s about bringing it to life so they can understand what’s expected, rather than setting out a particular provision of the regulation which gets you nowhere.”

Structure and clarity matter in AML training

Double clicking into the success factors, tell us more about the need for structure and clarity in AML training.

“For new employees or newly regulated Tranche 2 firms, the AML/CTF Act and Rules can feel overwhelming. There’s a huge amount to absorb - from designated services and CDD, through to PEPs, sanctions and suspicious matter reporting. And that’s just a few examples!

AMLCOs often tell me they don’t have the time or resources to develop clear, well-structured training. When firms try to deliver all of this at once, or in a one-size-fits-all session, staff tune out. And if they switch off, they’re not going to absorb what they need to."

Instead, Emma emphasises that structure means breaking training down so it feels manageable and relevant.

 "Think about when training happens - before go-live, at induction and then as regular refreshers. Make sure the content fits the role. AUSTRAC even specifically calls that out - staff need training for what they actually do and their responsibilities within the AML/CTF program. Whether that’s general awareness training for all staff to recognise risks and escalate, or customer due diligence training for operational and client onboarding teams, or governance-focused training for senior managers and boards. And don’t forget to check understanding - it’s not enough to deliver the session, you need to know people actually got it.”

For AMLCOs, clarity also means having a plan. Knowing which roles need which training, how often it will happen, and how completions and records will be tracked. “When you’ve mapped that out, you can stop worrying about gaps and start focusing on quality.”

• Timing - before implementation, induction training, refreshers
• Topics - topics relevant to roles
• Planning - format, how training records will be kept, knowledge checks so that staff have understood the training

Variety keeps people engaged

So you’ve spoken about structure and clarity in AML training, what about variety?

"Variety is what keeps it fresh and makes training stick. And importantly, variety is what makes sure that AML doesn’t equal boring. Just look at the popularity of true crime podcasts and shows! People are fascinated by stories of fraud and deception when they’re told in the right way. If you present AML through real-world case studies, and in an engaging way, suddenly it becomes compelling, not a chore.”

She’s quick to point out that variety also means recognising different learning styles. 

“Not everyone learns the same way and in our attention economy, where staff have a thousand things competing for focus, the best AMLCOs think about how best to engage staff. Some like to listen, others need visuals, others want to test themselves. Quizzes, videos, workshops, newsletters – the right mix depends on your people, systems and resources.”

Eloise Butterworth, Head of Risk and Compliance, HiveRisk, explains, "The best AMLCOs translate risk into real-world decisions. They speak clearly, listen carefully. What you say, and how you say it, matters."

Relevance makes it stick

Finally, tell us about relevance in relation to AML training

 “Relevance is a key ingredient. AML training isn’t about memorising the Act - it’s about showing staff what AML means for them in their role, their industry and in their daily work. If you’re using an external provider, make sure the courses or sessions are tailored to the Australian AML/CTF regime and to your industry sector, then further tailor it for your firm and roles.”

Relevance also means respecting time, especially in real estate and professional services, where speed is important and minutes are billable.

“The reality is, staff are not going to like AML much at the beginning, and are unlikely to embrace more steps and compliance, so the training becomes really important, but it needs to be clear and relevant.”

As Oscar Fransman of Simpson Grierson explained:

“When AML first kicked in, there was definitely some frustration. Our lawyers were used to jumping straight into the work, and suddenly we had to tell them, ‘You can’t start until we complete customer due diligence.’ Training made the difference. Once they understood that CDD is just another step in the process and that they need to plan for it, they adapted.”

The takeaway

The AML/CTF Act and Rules set out what you must do: train staff, refresh them regularly and keep records. But the firms that will thrive under Tranche 2 will go further. They’ll build training around structure and clarity, variety and relevance so that staff don’t just sit through a session, they actually take it in

As Emma summed it up, “The law gives you the ‘what’, but training is where you deliver the ‘why’. The win isn’t ticking off another annual course - it’s when your team understands AML well enough to apply it every day, without being pushed. That’s when training really works.”