AML/CTF Program & Implementation

✅ Program Complies

With:

  • AML Act 2006

  • AML/CTF Rules 2007

  • AUSTRAC’s guidance for reporting entities

  • FATF recommendations

  • Privacy Act

  • Tranche 2 readiness expectations (optional forms for legal/accounting firms already included)

✅Program Contains

    • A Implementation Guide

    • 3 Training Presentations

    • 4 Manuals (including Part A, B) & Guidelines

    • 14 Policies

    • 13 Procedures

    • 10 Forms & 4 Checklists

    • 11 Registers

    • 2 Other Helpful Documents.

    - See section below for full list of Documents.

    ✅Program Topics

    • Customer Due Diligence (Customer Identification and Verification)

    • Enhanced Customer Due Diligence (Heightened Scrutiny for Higher-Risk Customers)

    • Know Your Customer (Customer Identification and Risk Assessment)

    • Politically Exposed Persons (High-Risk Individuals)

    • Ongoing Monitoring (Continuous Monitoring of Customer Transactions)

    • Suspicious Matter Reporting (Reporting Unusual Transactions)

    • Threshold Transaction Reporting (Large Transaction Reporting)

    • International Funds Transfer Reporting (Tracking Cross-Border Transfers)

    • Record Keeping (Maintaining Transaction and Customer Records)

    • Risk Assessment (Identifying and Managing Risks)

    • Internal Controls (Policies and Procedures to Prevent Money Laundering)

    • Employee Training (Educating Staff on AML Procedures)

    • Independent Audits (External or Internal Review of AML Program)

    • Risk-Based Approach (Tailoring Compliance Based on Customer and Transaction Risk)

    • Governance (Oversight and Accountability of the AML Program)

    • Compliance Officer Role (Designated Person Responsible for AML Compliance)

    • Corrective Actions (Addressing Non-Compliance or Process Failures)

    ✅Implementation Guide

    • Sections in Order to Implement - 
      • Each section lets you know what part to focus on, what documents you need and what actions are required.

    • Rollout Plan and Possible Timeline

    • Common Challenges and Tips ie Apathy

    • AUSTRAC Audit Preparation

    • Ongoing Compliance

    ✅Document Info

    Designed to help you understand all the information and how to implement.

    Policies

    • Application

    • Purpose

    • Background

    • Applicable Legislation

    • Policy

    • Roles and Responsibilities

    • Applicable Exemptions

    • Definitions

    • Related Policies, Procedures, Registers, Forms, Checklists, Guidelines and Documents

    • Summary – Who, What, Why, When, Where, How

    • Compliance Actions

    • Non-Compliance

    • Document Management and Control

    • Key takeaways

    Procedures

    • Process Flow Chart

    • Purpose

    • Scope

    • Prerequisites / Requirements

    • Roles and Responsibilities

    • Step-by-Step Instructions

    • Decision Points

    • Expected Outcomes / Success Criteria

    • Troubleshooting / Common Errors

    • Related Documents / Links

    • Document Management & Control

    • Contact for Help

    • Key Takeaways

    Registers

    • All the applicable Heading Info

    • Examples of how to fill the register out

    • Version Control

    Forms

    • Explanation of the form

    • All the applicable info required to populate with room to write on the form or use checkbox.

    • Version Control

    Checklists

    • Description of what's required i.e. Obtain address?

    • Checkbox Y/N

    • Notes section

    • Version Control

    ✅ Help with Training

    ✅Ongoing Support

    Staff Training Slide Deck (PowerPoint)

    • AML Explained - Covers AML/CTF basics, SMRs, tipping off, CDD/KYC, PEPs, etc.

    • Senior Managers Training Presentation

    • Onboarding Specialist Training Presentation

    • Compliance team Training Presentation

    Training Declaration Form

    • For staff to sign off on having received AML/CTF training

    Training Evaluation Form

    • Staff can provide feedback.

    • Once in our database well keep you up to date with any changes

    • Regular AML Blogs on our Website

    • Reach out anytime - info@ops-on-demand.com

    ✅Program Documents

    Core Documents

    Record Keeping

    1 AML/CTF Program Part A
    2 AML/CTF Program Part B
    3 AML/CTF Policy Manual
    4 AML/CTF Risk Assessment
    5 AML/CTF Risk Assessment Register
    6 How to Complete AML Risk Assessment
    7 Change Management & Version Control Policy
    8 Change Management Procedure

    37 Record Keeping Policy

    Employee AML Training & Oversight

    38 Employee AML Training Policy
    39 Training Delivery Procedure
    40 Training Attendance Register
    41 AML Confidentiality Acknowledgement / Staff Agreement
    42 Training Evaluation Form

    Customer Due Diligence

    Governance & Outsourcing

    9 Customer Due Diligence (CDD) Policy
    10 Customer Due Diligence (CDD) Procedure
    11 Customer Due Diligence (CDD) & Know Your Customer Forms -Individuals
    12 Customer Due Diligence (CDD) & Know Your Customer Forms -Entities
    13 Customer Risk Rating Register
    14 Customer Verification Documents Register

    43 Outsourcing & Third-Party AML Controls Policy
    44 Outsourcing Due Diligence Checklist
    45 Outsourcing Due Diligence Register
    46 Compliance Officer Appointment Template

    Enhanced Due Diligence

    Audit and Review & Reporting

    15 Enhanced Due Diligence (EDD) Policy
    16 Enhanced Due Diligence (EDD) Procedure
    17 Enhanced Due Diligence (EDD) Assessment Template

    47 Independent Review Procedure
    48 Audit and Review Register
    49 Annual Program Review Checklist
    50 Internal Audit Checklist
    51 AML/CTF Compliance Reporting Procedure
    52 AUSTRAC Feedback Response Procedure

    Beneficial Owners

    Privacy

    18 Beneficial Ownership (BO) Policy
    19 Beneficial Ownership (BO) Verification Checklist
    20 Beneficial Ownership (BO) Declaration Form
    21 Beneficial Ownership (BO) Register

    53 Privacy and Data Protection Policy

    Politically Exposed People

    Breach Reporting

    22 Politically Exposed Persons (PEP) Policy
    23 Politically Exposed Persons (PEP) & Sanctions Check Guidance Sheet
    24 Politically Exposed Persons (PEP) & Sanctions Escalation Approval Form
    25 Politically Exposed Persons (PEP) & Sanctions Screening Register

    54 Breach Reporting Policy
    55 Breach Reporting Procedure
    56 Breach Internal Report Form
    57 Breach Reporting Register

    Transaction Monitoring & Reporting

    Helpful Docs

    26 Suspicious Matter Reporting (SMR) Policy
    27 Suspicious Matter Reporting (SMR Lodgement Procedure
    28 Suspicious Matter Reporting (SMR) Form
    29 Suspicious Matter Reporting (SMR) Register
    30 Threshold Transaction Reporting (TTR) Policy
    31 Threshold Transaction Reporting (TTR) Lodgement Procedure
    32 Threshold Transaction Reporting (TTR) Reporting Form
    33 Threshold Transaction Reporting (TTR Register
    34 International Funds Transfer Instructions (IFTI) Policy
    35 International Funds Transfer Instructions (IFTI) Lodgement Procedure
    36 International Funds Transfer Instructions (IFTI) Register

    58. Customer Complaints Procedure

    59. How to - Change Request Form

    60. Board Reporting Form

    Q - How long would it take you to research and write all those documents?

    A - 80 hours? 100 Hours? More???