Changing minds, not just processes: How to deliver internal comms for AML

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By mid-2026, every meeting, client and transaction will touch AML in some way. Policies and systems will be essential - but they’ll mean little if people don’t change how they think.

Firms often underestimate this. They publish a polished AML policy, run one training session and assume compliance will “stick.” It rarely does.

"Don't underestimate how long it takes. Writing policies is the easy part. Getting people across them, and working to them, takes far longer."
Gary Spalding, Dentons

Behaviour doesn’t shift through documentation - it shifts through communication, repetition and reinforcement. Here’s how to make AML part of your culture, not just your checklist.

Start with why, not what

People don’t rally behind rules - they rally behind reasons. When AML is framed as regulation, it feels imposed. When it’s framed as protection, it feels shared and purposeful.

Start your rollout with the story behind the rule:

“AML isn’t about paperwork - it’s about protecting people. This is because money laundering isn’t a victimless crime. It cleans profits from drug trafficking, terrorism, human exploitation and fraud. In Australia, it’s estimated that up to 2.3% of GDP ($43.6 billion) is laundered here every year. So each ID check is a small act of protection; keeping crime out of our communities, profession and industry.” 

Purpose turns obligation into ownership - the foundation of cultural change.

“Explain to them 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.”
Michelle Garlick, Weightmans

Repeat what matters

People forget fast — up to 90% of new information within a week. That’s why AML awareness needs rhythm, not one-offs. Create a steady drumbeat of reminders:

• An initial kickoff session
• A short “AML minute” at team meetings
• On-desk reminder cards
• Monthly internal posts
• Refreshers tied into AML training

Each reminder triggers the same cue: pause and check. Over time, that’s how habits form.

Speak to different needs

Everyone plays a role in AML, but not everyone needs the same message. AUSTRAC expects training - and by extension, communication - to reflect each person’s role and risk.

• A partner might worry about client relationships.
• A junior might fear making a mistake.
• An administrator might not know where to start.
• A board member might ask what it will cost.

When communication feels relevant, it lands.

• For leaders: “As directors, we’re accountable for proving our AML program works in practice, not just on paper.”
• For client-facing teams: “Here’s how to explain AML without losing rapport.”
• For support staff: “Step 1: run the risk assessment. Step 2: collect ID. Step 3: record verification. Step 4: escalate if needed.”

Tailoring by audience shows respect, and that respect drives engagement.

"The biggest shift for us was training our agents properly. Once they understood their obligations, why it mattered and what could happen if things went wrong, they were quick to get on board.”
Brendon Pierce, Arizto Real Estate

Model what you want to see

Action speaks louder than words. If leaders cut corners, others will follow. If leaders treat AML as everyday professionalism, that becomes the norm. 

Show, don’t tell:

• Partners complete onboarding like everyone else.
• Leaders attend training alongside their teams.
• Senior people publicly acknowledge good AML practice.

When people see those at the top doing it right, compliance stops being “their job” and starts being “our standard.”

Make it easy to do the right thing

Behaviour follows cues. If AML processes feel separate or awkward, people will resist. When it’s part of everyday systems and language, it becomes instinctive. Use small design signals to reinforce behaviour:

• Default AML messages in matter templates and client comms.
• Standard AML phrasing in email signatures or file notes.
• Simple on-screen reminders that normalise verification steps.

Design your communications environment the same way you design your systems - to make the right thing the easy thing.

Refresh the content not the message

Training must evolve without diluting the message. Keep the core consistent - why AML matters, when to apply it, how to escalate - but vary how it’s delivered.

Use variety:

• Live sessions with examples from real clients or AUSTRAC cases
• Micro-videos or quick quizzes between meetings
• Short scenario games that spark discussion

Different formats reach different learners, but repetition of the core ideas builds shared instincts.

Keep AML visible in leadership conversations

AUSTRAC expects AML to appear regularly in board and oversight meetings, but visibility is more than compliance. It’s commitment.

Ask the same questions every quarter:

• Are our risk assessments current?
• Do we have enough resourcing for verification?
• What trends are we seeing in flagged cases?
• Have new services created new obligations?

When staff see leaders tracking these issues, they understand that AML isn’t a side project. It’s how the firm protects itself, and its clients, from real-world harm.

Habits before handbooks

Changing behaviour takes time and trust. It’s built through stories, consistency and systems that make the right action automatic.

If every message, meeting and transaction reinforces that AML is how we work (not extra work) compliance becomes part of the firm’s identity.

Because in the end, AML isn’t about process. It’s about purpose.