Review inputs

Some of the inputs may include:

• whether the AML/CTF program is working effectively
• measures of the extent to which objectives and targets have been met.

Other examples include, but are not limited to:

• the extent and effectiveness of the staff AML/CTF awareness training
• the completion of appointments of staff to AML/CTF roles
• the performance of staff in AML/CTF activities
• the completion of AML/CTF compliance reporting
• the lodgement of AUSTRAC reports
• assessing the effectiveness of communications between the board and senior management, the AML/CTF Compliance Officer and the operational areas conducting AML/CTF actions
• outputs of employee due diligence measures
• AUSTRAC feedback.

Review outputs

The outputs of the review are its findings and recommendations which should be documented and provided to the governing board or senior management of the reporting entity. In relation to a designated business group, this means the board/management of each reporting entity in the group.

The findings should address the review inputs and provide statistics that support these results. Any instances and episodes that were not expected in the AML/CTF program's implementation plan should be described. Any cases or examples from the business's experience of implementing and managing its AML/CTF program that provide the business with a better understanding and insight into its own processes and culture of compliance may also be documented.

The recommendations include, but are not limited to:

• corrective actions to address compliance failures
• changes to improve the AML/CTF program
• changes to both compliance and operational processes to improve the management of:
• ML/TF business risks
• ML/TF regulatory risks.