Tranche 2 deadline: July 1, 2026
AUSTRAC's program starter kits are 100+ pages each. This summary breaks down the essentials so you can build your AML/CTF program fast.
What is an AML/CTF Program?
An AML/CTF Program is your business's written plan for complying with Australia's Anti-Money Laundering and Counter-Terrorism Financing laws. Think of it as your compliance instruction manual.
AUSTRAC provides industry-specific "starter kits" to help you build yours. But they're dense—100+ pages of legal terminology. This guide summarizes the key components you actually need.
The 5 Core Components of Every AML/CTF Program
1. Part A: Customer Identification & Verification (CDD)
What it covers:
- Who needs to be verified (individuals, entities, beneficial owners)
- What documents you accept (driver's licence, passport, ACN/ABN)
- How you verify identity (biometric checks, registry lookups)
- When verification happens (before service, during onboarding)
Practical checklist:
- Document which ID types you accept for individuals (minimum 1 from government list)
- Explain how you verify entities (ASIC registry, ABR, trust deed)
- Define beneficial ownership threshold (25%+ ownership or control)
- Specify timing: "We verify identity before signing contracts"
2. Part B: Ongoing Customer Due Diligence (OCDD)
What it covers:
- When you re-verify existing clients
- Triggers for enhanced due diligence (high-risk clients)
- Review schedules (annually, every 2 years, etc.)
Practical checklist:
- Set review frequency: Low-risk (36 months), Medium (24 months), High (12 months)
- Define red flags requiring enhanced checks (PEP, high-value, offshore)
- Document how you track review dates (calendar, CRM, compliance software)
3. Risk Assessment
What it covers:
- How you assess client money laundering/terrorism financing risk
- Risk factors you consider (industry, transaction type, geography)
- Risk rating system (Low, Medium, High)
Practical checklist:
- List risk factors: customer type, service type, delivery method, geography
- Create risk matrix: assign points to each factor, total = risk rating
- Document examples: "Cash transaction >$50k = +3 points (High risk)"
4. Suspicious Matter Reporting (SMR)
What it covers:
- When you must file a Suspicious Matter Report with AUSTRAC
- Who is responsible for deciding to report
- How you submit reports (AUSTRAC Online)
Practical checklist:
- Define red flags: AML watchlist match, PEP, unusual transaction patterns
- Name the decision-maker: "Principal/Senior Managing Official reviews"
- Document reporting timeline: "Within 24 hours of suspicion"
5. Record-Keeping & Training
What it covers:
- What records you keep (CDD reports, transaction records, risk assessments)
- How long you keep them (7 years minimum)
- Staff training requirements (who, how often, what topics)
Practical checklist:
- List what you store: CDD reports, transaction records, SMRs, training logs
- Specify retention: "7 years from end of relationship or transaction"
- Training plan: All staff annually, new hires within 30 days
Industry-Specific Requirements
Real Estate Agents
- Verify buyers, sellers, landlords, tenants before contracts
- Include property address in transaction records
- Higher risk: cash deposits, offshore buyers, luxury properties
Accountants & Tax Agents
- Verify all clients providing designated services (tax prep, financial advice)
- Document service type in CDD records
- Higher risk: cash-intensive businesses, complex structures, offshore entities
Lawyers & Conveyancers
- Verify before providing legal services or handling trust funds
- Include matter type in records (property, estate, corporate)
- Higher risk: large cash settlements, complex trusts, litigation funding
Jewellers & High-Value Dealers
- Verify any transaction over $10,000
- Include item description and value in records
- Higher risk: cash payments, repeat large purchases, resale indicators
Free Program Template
FreeAML provides a free AML/CTF Program generator. Answer a 5-minute questionnaire and get a customized 20-page program document matching AUSTRAC's requirements.
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