Who must designate an AML/CTF Compliance Officer?

Reporting entities must designate an eligible AML/CTF compliance officer at management level and notify AUSTRAC.

Reporting entities must designate an AML/CTF compliance officer who is employed or engaged at management level, is a fit and proper person, and (where services are provided through an Australian permanent establishment) is an Australian resident. The officer needs sufficient authority, independence and resources. Designation is due within 28 days of first providing a designated service, and AUSTRAC must be notified within 14 days of designation; newly regulated Tranche 2 entities notify by the later of 29 July 2026 or 14 days after enrolling. Check AUSTRAC's compliance officer guidance before relying on an outsourced arrangement — outsourcing does not transfer liability.

Applies when the business has an AML/CTF designated service. Where the business has aml adjacent, check whether you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).

How the regulator frames it: All AUSTRAC reporting entities.

What triggers it: Becoming a reporting entity.

Jurisdiction: Commonwealth law, so the test is the same in every state and territory.

Outcome across the 35 industries Rules Mate maps (8 of 35: yes; 27 of 35: no).

Structure does not change the answer in the 8 industries it can reach: for every structure the answer is "yes".

Size does not change the answer in the 8 industries it can reach: at every size band the answer is "yes".

Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:

• Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: applies. Tranche 2 industry (Real estate agents) — AML/CTF reporting entity from 1 July 2026.
• Pty Ltd company in fintech (non-bank) with 6–19 employees, turnover $1M–$3M: does not apply. Requires an AML/CTF designated service.

Starting from a small or large professional services company that does not otherwise meet the test, each of these single facts changes the engine's answer:

• The business holds an Australian financial services licence (AFSL): it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
• The business issues financial products or gives financial product advice: it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
• The business holds an Australian credit licence (ACL): it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
• The business provides credit to customers: it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
• The business deals in crypto-assets or runs a digital currency exchange: it then applies (digital currency exchange / virtual asset services — AML/CTF reporting entity).
• The business receives large physical cash payments: it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
• The business makes or receives international funds transfers: it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).

The engine shows this obligation as "check whether this applies" when a business has aml adjacent. It then applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3). That fact is not something Rules Mate can infer from industry, structure or size.

When due

Designate within 28 days of first providing a designated service; notify AUSTRAC within 14 days of designation and of any change.

Frequency

Ongoing

Evidence to keep

Designation record; fit-and-proper assessment; position description; AUSTRAC notification record.

Status

Current

Priority

Critical

Maximum penalty: Civil penalties to the AML/CTF Act maximum; AUSTRAC remediation.

Independent review. Authority: Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ss26F(2), 26F(4)(f), 26H, 116 (compilation C62, in force 1 Jul 2026); AML/CTF Rules 2025 (F2025L01026) r5-10; AML/CTF Transitional Rules 2026 (F2026L00393) Part 7; AUSTRAC "Step 5: Conduct an independent evaluation" (last updated 31 Mar 2026).

Frequency: At least once every 3 years, at the frequency set in your AML/CTF policies (documented rationale). Transitional first-evaluation deadlines (30 Jun 2029 to 31 Dec 2030) depend on the last two digits of your AUSTRAC account number and on when you first provided the designated service.

Who can perform it: An evaluator who is independent: internal (for example internal audit) or external, but not your AML/CTF compliance officer or compliance team, and not anyone who developed the program or assessed your ML/TF risk. No mandatory qualifications. The evaluator reports in writing to your governing body and the senior manager who approves the program. Separately, AUSTRAC can require an external audit by an AUSTRAC-authorised auditor by written notice (ss161-162).

If this obligation applies to you, so do these 7: the engine uses the same rule for each.

• Enrol with AUSTRAC as a reporting entity
• Maintain a written AML/CTF program
• Customer due diligence (KYC) on every customer
• Suspicious matter, threshold, and IFTI reporting to AUSTRAC
• Independent review of AML/CTF program
• Detect + enhance due diligence on Domestic + Foreign PEPs
• Lodge the AUSTRAC annual compliance report (AML/CTF Act s 47)

Across the 1,890 business profiles Rules Mate evaluates, these obligations apply to most of the businesses this one applies to, and are far more common among them than among businesses generally:

• Comply with Australian sanctions law + screening (DFAT): applies to 100% of the same businesses (4.4× the overall rate)

Rules Mate tracks 8 published obligations tagged "aml ctf", 6 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated critical priority, and is an ongoing duty.

Regulated by Australian Transaction Reports and Analysis Centre.

AUSTRAC: Anti-money laundering and counter-terrorism financing regulator and financial intelligence unit. Administers the AML/CTF Act, including Tranche 2 expansion from 1 July 2026.

• Australian Transaction Reports and Analysis Centre

AML/CTF Act: Federal AML/CTF regulation.

• Anti-Money Laundering and Counter-Terrorism Financing Act 2006

Free tools that help with this obligation:

• AML Tranche 2 scope checker
• Beneficial owner identifier
• Compliance calendar builder