If your business operates in Australia it will probably already have risk management policies, strategies and procedures in place to be compliant with other regulatory obligations, for example:

• workplace relations
• workplace discrimination and bullying
• occupational health and safety.

In this case you are likely to have resources that you can draw upon for your ML/TF risk management. Using these resources will also help you to make AML/CTF a part of your normal business practices.

A primary goal of an AML/CTF program is that it should effectively manage the business risks that the business may be used for money laundering or terrorism financing. The primary purpose of Part A of your AML/CTF program is to identify, manage and mitigate the ML/TF risks your business may reasonably face and then deciding how you respond to that assessment. Equally important, and required under section 116 of the AML/CTF Act, is that you document the implementation of your program and retain records of any variations to the program. It may also be beneficial to measure and record how well the program is achieving your specific risk management goals.

The AML/CTF Act requires reporting entities to have a written AML/CTF program comprising Part A (general) and Part B (customer identification). Part A concerns implementing organisational changes in a business. Part B can be described as procedural changes relating to how an organisation determines who its customers are and continuously manages its customer relationships for the purpose of preventing ML/TF. Part B is covered in module 3.

Part A of an AML/CTF program must address the following organisational requirements:

• oversight of the AML/CTF program by boards and senior management
• ML/TF risk awareness training program for employees
• employee due diligence
• appointment of an AML/CTF Compliance Officer
• independent review of AML/CTF program effectiveness and compliance
• processes for assessing and incorporating AUSTRAC feedback to continuously improve AML/CTF procedures
• risk management systems and controls for managing ML/TF vunerabilities in any permanent establishment in a foreign country.