Who can hold the role
The officer must be at management level, with the authority to make the program work: to stop a service until identification is complete, to lodge a report, to require training. They should be a fit and proper person. A sole practitioner is their own compliance officer.
What the role involves
- Owning the AML/CTF program: adopting it, reviewing it yearly and when things change.
- Deciding on higher-risk clients: approving enhanced due diligence and, if needed, declining the service.
- Lodging suspicious matter, threshold transaction and annual compliance reports.
- Making sure staff are trained and records are kept.
- Being AUSTRAC's contact point.
How much time it takes
For a firm with a few hundred clients and no cash: an afternoon to set up, an hour a month to review what is due, and a half day once a year for the program review and staff training. The time goes up with cash, trusts and overseas clients, because those bring more high-risk files.
Record the appointment
Name the officer in your program and in your AUSTRAC enrolment. When the officer changes, update both and note the date.
Questions people ask
- Can an external consultant be our compliance officer?
- The role must sit at management level inside the reporting entity. You can get outside help, but the accountable person is yours.
- Does the officer need a qualification?
- No specific qualification is required. They need to understand the firm's obligations and have the authority to enforce them.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.