AML/CTF Program (AUS)
Your complete AML solution—ready to go!
π― Who It’s For?
βοΈ Lawyers, Conveyancers, Accountants, Bookkeepers
π’ Real Estate Agents, Crypto Businesses
π Any DNFBP covered under Tranche 2
ποΈ Small businesses that want to avoid $10k+ consultant fees

β 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)
β Program Contains
- An Implementation Guide
- 2 Manuals (including Part A, B) & Risk Assessment
- 14 Policies
- 13 Procedures
- 10 Forms & 4 Checklists
- 11 Registers
- 3 Training Presentations and other help documents
β Program Topics
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Customer Due Diligence (CDD) – Identify and verify customers before providing services.
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Enhanced Due Diligence (EDD) – Apply stricter checks to high-risk customers, trusts, and PEPs.
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Know Your Customer (KYC) – Understand customer type, source of funds, and purpose of the relationship.
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Politically Exposed Persons (PEPs) – Identify and monitor high-risk individuals and their associates.
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Ongoing Customer Due Diligence (OCDD) – Continuously monitor customers and update CDD when needed.
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Suspicious Activity Reporting (SARs) – Report suspicious behaviour to the FIU using goAML.
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Prescribed Transaction Reporting (PTRs) – Report cash transactions ≥ $10,000 and international transfers.
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International Funds Transfer Reporting – Track and report cross-border transactions as part of PTR obligations.
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Record Keeping – Keep identity, CDD, and transaction records for at least 5 years.
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Risk Assessment – Conduct and document a risk assessment before implementing your AML/CTF program.
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Internal Controls – Establish policies, procedures, and systems to mitigate ML/TF risk.
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Staff Training – Deliver AML training to all relevant staff regularly.
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Independent Audit / Review – Have the program reviewed every 2 years or when required by your supervisor.
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Risk-Based Approach – Tailor compliance activities based on assessed risk.
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Governance and Oversight – Ensure board/senior management approves and supports the program.
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Compliance Officer Role – Appoint a competent individual to manage AML/CTF compliance.
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Corrective Actions & Breach Management – Have a clear process to manage failures, breaches, and remedial actions.