Who can hold it
A person employed or engaged by the practice at management level, with the authority to make the program work: to hold a matter until identification is complete, to lodge a report, to require training. They must be a resident of Australia if you provide services through a permanent establishment here, and a fit and proper person, which you must assess before appointing them and keep a record of. A sole practitioner is usually their own compliance officer. Appoint the officer within 28 days of first providing a designated service and notify AUSTRAC within 14 days of the appointment. Under the Transitional Rules 2026, firms that enrolled at commencement had until 29 July 2026 or 14 days after enrolling, whichever was later.
What it involves
- Owning the program: adopting and reviewing it.
- Approving enhanced due diligence and declining matters where needed.
- Lodging suspicious matter, threshold transaction and annual compliance reports.
- Ensuring staff are trained and records kept.
- Being AUSTRAC's contact.
Time it takes
For a small practice with no cash and a normal client base: an afternoon to set up, an hour a month, and half a day a year for the program review and training.
Questions people ask
- Can our external accountant be the officer?
- You can outsource the role, but the person must still meet the eligibility requirements: management-level authority in your practice, Australian residency where applicable, and fit and proper. You remain responsible for the role being performed properly.
Sources
Official AUSTRAC guidance this page was checked against. The date is when we captured the page; AUSTRAC may have updated it since.
- AML/CTF compliance officer · AUSTRAC, captured 17 May 2026
- Governance and oversight for sole traders and micro businesses · AUSTRAC, captured 17 May 2026
This guide is general information for solicitors, conveyancers, settlement agents, not legal advice. Check AUSTRAC's current guidance for your situation.