Why must training be completed before doing VOI transactions?
The platform gates transactional access on training completion because AUSTRAC expects firms to ensure staff are competent to perform AML functions before they are allowed to do so.
The platform gates transactional access on training completion - a user can't initiate or sign off VOIs until their mandatory modules are complete. There are also other sections of the platform that sit behind a training gate that access is granted after training modules are complete. The gate exists because AUSTRAC's framework expects firms to ensure staff are competent to perform AML functions before they're allowed to do so; allowing untrained staff to perform CDD would breach that expectation and the firm's AML/CTF Program.
What this looks like in practice:
- Newly invited user completes registration and MFA, lands on dashboard, sees training modules to complete.
- Training in progress - the user can navigate the platform and view existing transactions but the "Create Transaction" workflow is locked.
- Training complete - the lock releases and full role-based access is available.
The gate is technical rather than advisory - to be certain of compliance training should be completed. However, it can be released by the Compliance Officer granting a documented training exemption (see 'Can the Compliance Officer grant training exemptions to bypass the mandatory training gate?' below). For genuine time pressure (a new hire urgently needed to clear a backlog), we generally recommend that you assign existing trained staff to the urgent work and let the new hire complete training in parallel.
See AUSTRAC's AML/CTF Program reform for the training-competence expectation.