AML/CTF Compliance Officer (AMLCO) — role and statutory responsibilities

Statutory requirement

The reformed AML/CTF Act requires every reporting entity to designate an AML/CTF Compliance Officer (AMLCO) at management level as part of the governance of its AML/CTF program (under the former structure this sat in Part A), and to notify AUSTRAC within 14 days of designation. This designation is a fundamental requirement for compliance with the AML/CTF Act, Regulations and Rules. Reporting entities must ensure their AMLCO is appropriately appointed and has the necessary authority. AUSTRAC enrolment 31 March 2026 walkthrough

The AMLCO holds responsibility for overseeing compliance with the AML/CTF Act, Regulations and Rules. The structure of this role varies; smaller entities may designate an existing employee already in a senior compliance position, while larger entities typically establish a dedicated AMLCO function.

AUSTRAC requires the AMLCO to possess sufficient seniority and authority to direct compliance action within the reporting entity. As part of the entity's enrolment, the AMLCO's contact details must be provided to AUSTRAC.

Core responsibilities

The AMLCO has core responsibilities relating to the day-to-day oversight of an entity’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program. This includes ensuring that suspicious matter reports are reviewed and lodged on time, as mandated under section 41. Similarly, the AMLCO is responsible for ensuring that threshold transaction reports (TTRs), international funds transfer instructions (IFTIs), and accounts created reports (ACRs) are lodged on time, in accordance with sections 43, 45 and 47 respectively. AUSTRAC reporting deadlines table provides further detail.

A key function of the AMLCO is to act as the principal point of contact with AUSTRAC. This facilitates communication and ensures the entity’s compliance obligations are met. The AMLCO must also ensure that transaction monitoring rules are operating and appropriately tuned to detect potential illicit activity.

Finally, the AMLCO is responsible for ensuring that enhanced customer due diligence (ECDD) is applied where required. This is a critical component of a robust AML/CTF program.

Board and senior management interaction

The AMLCO’s role involves regular interaction with the board or a senior risk/audit committee. This interaction focuses on reporting the performance of the AML/CTF program. Reporting includes updates on the AML/CTF program and its effectiveness.

Material issues require escalation to the board or senior management. These issues include significant Suspicious Matter Report (SMR) volumes, identified gaps in controls, and direct contact with regulators.

Ultimately, the governing body and senior manager remain accountable for the AML/CTF program. The AMLCO helps ensure the independent evaluation of the whole program (at least once every 3 years) is conducted and any findings are remediated.

Personal exposure

AMLCOs are exposed to personal civil penalties. Accessorial liability provisions mean an AMLCO can be held responsible personally for contraventions of the Anti-Money Laundering and Counter-Terrorism Financing Act.

Tipping-off offences, as outlined in section 123, also apply to AMLCOs. This means they are subject to the same restrictions and potential penalties as other officers regarding the disclosure of information.

AUSTRAC has demonstrated a willingness to pursue individual officers, alongside entities, when compliance failings are identified. Maintaining adequate resources and documented succession planning, alongside clear reporting lines, can provide evidence of due diligence and offer some protection against assertions of inadequate program controls.