Staff Training Obligations for TCSPs Under Tranche 2
Australian TCSPs must maintain an AML/CTF staff training programme under Part A of their compliance programme. Here is what the obligation requires.
Australian trust and company service providers (TCSPs) must maintain an ongoing AML/CTF staff training programme under Part A of the AML/CTF Act 2006. Training obligations commenced on 1 July 2026 — every employee with AML/CTF responsibilities must complete training before handling those duties, and training records must be kept for seven years.
What does Part A require for TCSP staff training?
Part A of every AML/CTF programme must include an ongoing employee due diligence and training framework. For TCSPs, that means defining who must be trained, what the training must cover, how often it recurs, and how completion records are maintained. AUSTRAC treats the absence of a documented training programme as a Part A contravention.
Who at a TCSP must complete AML/CTF training?
The obligation applies beyond the AMLCO. Any staff member who onboards clients, provides a designated service — company formation, trust administration, nominee arrangements, or registered office services — or exercises AML/CTF judgement must be trained. Purely administrative staff with no AML/CTF function may be excluded, but the programme must document why.
What must AML/CTF training cover for TCSPs?
Training for TCSPs must go beyond generic DNFBP content. AUSTRAC expects programmes to cover: - AML/CTF Act obligations — designated services, reporting entity duties, and civil penalty consequences for non-compliance - TCSP-specific red flags — nominee arrangements without clear rationale, clients resisting beneficial ownership disclosure, and unusual trust account fund flows - CDD procedures — identity collection, beneficial ownership mapping, and enhanced due diligence triggers - Suspicious matter reporting — SMR thresholds, reporting deadlines, and the tipping-off prohibition
How often must TCSPs renew AML/CTF training?
The AML/CTF Act 2006 requires training to be ongoing, not a one-off event. Your Part A must define a refresh frequency — annual re-training is the standard for most firms. Training must also be updated when designated services change or AUSTRAC issues new TCSP-sector guidance. New employees must complete training before they begin any AML/CTF functions. AMLify for TCSPs includes a built-in training module with automatic completion tracking and seven-year record retention.
Key Takeaways
- Staff training is mandatory under Part A — active from 1 July 2026 and a standard AUSTRAC supervision check
- All AML/CTF-active staff must be trained — not just the AMLCO, but client-facing staff and designated service providers
- Training must reflect TCSP-specific risks — nominee arrangements, beneficial ownership, and sector-specific red flags
- Annual re-training is the expected minimum — Part A must document the refresh schedule and require completion before new staff begin AML/CTF functions
- Records are kept for seven years and produced to AUSTRAC on demand; AMLify for TCSPs automates this
Frequently Asked Questions
Q: Is AML/CTF training mandatory for sole-practitioner TCSPs?
Yes. Sole practitioners are not exempt under the AML/CTF Act 2006. If you are the sole principal and AMLCO, Part A must document that you have completed training commensurate with each role. Records must be created and retained for seven years.
Q: What happens if a TCSP has no training records during an AUSTRAC review?
AUSTRAC routinely requests training logs during supervision reviews. An absence of records is treated as a Part A contravention — evidence of a systemic programme failure rather than an isolated gap. Civil penalties apply for substantive programme contraventions under the AML/CTF Act 2006.
Q: Does generic AML/CTF training satisfy a TCSP's obligation?
Only if it addresses the firm's specific designated services and TCSP risk profile. Generic DNFBP training that skips nominee arrangements or beneficial ownership mapping is unlikely to satisfy AUSTRAC in a supervision review. Sector-calibrated training is the more defensible approach.
This is general information only and not a substitute for legal advice.