CC-101 · Lesson 2 · It is the service, not the job title

Your job title has nothing to do with it

The most common question in an agency is "does this apply to me?" It is the wrong question, and the right one is easier to answer.

23 September 2026 · Amanda Dunn · 4 min read

When AML/CTF obligations arrive, the first instinct is to sort people into who is covered and who is not. Sales agents yes, property managers maybe, reception no. It feels orderly.

It is also the wrong shape of question, and it produces confident wrong answers.

The law looks at what is being done

The framework works by naming particular services. Provide one of those services, and the obligations follow. Your title, seniority and whether you thought of yourself as "doing compliance" are all beside the point.

Two people with identical titles, sitting at adjacent desks, can be in different positions on the same afternoon — because one is doing something the law has named and the other is not.

That is why the useful question is not "am I covered?" but "what am I doing right now, and is this one of the named services?"

Why this catches people out

Three predictable ways:

Someone assumes they are exempt because of their title, and skips a step that attached to the work rather than to them.
A firm trains only the obvious roles, and misses the person who covers reception on a Saturday and takes the first enquiry.
A business decides it is too small to be in scope. Size is not the test.

Whether your particular business is captured, and which of its activities are caught, is a question for AUSTRAC’s guidance or your own adviser. We are a software company and that determination is not ours to make. What we can say is that the test is about the activity, so an answer built on job titles is standing on the wrong foundation.

What to do with that

Train wider than you think you need to. The cost of including someone who turns out not to need it is an hour. The cost of excluding someone who did is a gap in your program that appears at exactly the wrong moment.

And write down who you decided was in scope and why. That reasoning is part of your program, and the version of it that lives in someone’s head is not.

You are a reporting entity. So what changes? →The obligation sits with the business, and it does not move.

Where Curlew fits

Curlew keeps your people and your customers in the same system, so the question "who did this, and were they meant to?" has an answer. Team members carry roles, the designated compliance officer is recorded as a named person, and personnel due diligence and training sit against the individual rather than in a spreadsheet someone maintains.

When a customer file is opened, the due diligence is the same shape whoever opened it. That consistency is most of what an assessor is looking for.