Part A of an AML/CTF program must enable a reporting entity to:

• identify significant changes in the risk associated with money laundering or terrorism financing it faces
• recognise such changes in ML/TF risks for the purposes of the requirements of Part A and Part B of its AML/CTF program
• assess the ML/TF risk posed by:
  • all new designated services before introducing them to the market
  • all new methods of designated service delivery before adopting them
  • all new or developing technologies used to provide a designated service before adopting them

• determine the appropriate level of employee due diligence to apply to its employees, agents and consultants who carry out functions connected with the designated services and who are in a position to facilitate an ML/TF offence
• design, having regard to ML/TF risks it might reasonably face, a staff ML/TF risk awareness training programs and determine the frequency and extent of that training.

An AML/CTF program's Part A must include the following elements:

• ML/TF risk awareness training program
• ongoing customer due diligence (from 12 December 2008)
• oversight by board and senior management
• a designated AML/CTF Compliance Officer
• regular independent reviews
• dealing with AUSTRAC feedback
• permanent establishments in a foreign country.

Module 2 of the AML/CTF programs e-learning course will provide detailed information on Part A components of an AML/CTF program.