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Can the Compliance Officer grant training exemptions to bypass the mandatory training requirements?

Yes, the CO can grant per-user, per-module exemptions via Training Dashboard, releasing a staff member from a specific module requirement.

Yes - the Compliance Officer can grant an exemption to any individual staff member for any training module, releasing them from the training requirement for that module without completing it.

How to grant an exemption:

  1. Navigate to Training → Training Dashboard.
  2. Scroll to Staff Training Status.
  3. Find the staff member in the list and click View under Actions.
  4. The Staff Training Details panel opens showing each training module assigned to that user.
  5. Click Grant Exemption on the module you want to bypass.
  6. Enter:
    * Reason for Exemption (required) - the justification, e.g. "Staff member has completed equivalent training with [provider name]" or "Holds [external certification] covering the same content".
    * Exemption End Date (required) - the date the exemption expires, at which point the staff member is expected to complete the module. For an open-ended exemption, pick a date well in the future.
  7. Click Grant Exemption.

The exemption is recorded against the staff member with the reason and end date. The platform's training gate releases for that module, and the user can access parts of the platform that were blocked pending training completion eg perform CDD now without completing required training modules.

Compliance considerations

The training gate exists because AUSTRAC's framework expects staff to be competent to perform AML functions before they're allowed to do so. Granting an exemption shifts the basis for that competence from "completed easyAML training" to "the CO has documented why this person is competent without it". The CO remains accountable for the decision.

The platform displays a "Be aware of your compliance obligations" warning at the point of granting the exemption as a deliberate reminder of this responsibility.

When exemptions are reasonable:

  • Staff who have completed equivalent AML training with another recognised provider, where the content covers the same regulatory framework and CDD workflow.
  • 2IC arrangements where the deputy already holds AUSTRAC-aligned training from another reporting entity they work for.
  • External auditors with read-only access where the easyAML training isn't applicable to their role.

When exemptions are risky:

  • Granting exemptions for convenience or speed without genuine equivalent training behind them.
  • Long or open-ended exemptions where the staff member has no documented alternative competence.
  • Exempting staff from sector-specific training (e.g. Real Estate, Conveyancing) where the content is specific to the regulatory framing for that sector and easyAML's workflow.

The reason field and the end date are audit-visible. In an AUSTRAC review or independent evaluation, an exemption with a thin reason and a far-future end date will be difficult to defend.

Cross-references

  • "Why must training be completed before doing VOI transactions?" - the training gate can be released via the exemption mechanism described here.
  • "What happens when the CO goes on extended leave?" / "Can two separate businesses be CO / 2IC for each other's accounts during leave?" - exemptions are particularly useful where a 2IC has equivalent training from another firm.

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