Part A of a reporting entity's AML/CTF program must be approved by its governing board and senior management. Board and senior management oversight should also include a review, at set intervals, of the continuing adequacy of the AML/CTF program.

Corporate governance should reflect the structure of a business and demonstrate the philosophy and commitment of its leadership to manage and control its obligations. Corporate governance holds the business's leadership accountable to ensure that AML/CTF processes are developed and implemented and to ensure its control systems facilitate effective monitoring to allow senior management to provide feedback and direction as required.

Communication of AML/CTF policies from management to staff and the flow of ML/TF risk management information up and down the entity's hierarchy are extremely important. Management needs to be confident that controls are in place, that the costs and effectiveness of the AML/CTF program is being measured, that record keeping and compliance reporting processes - both within your business and to AUSTRAC - are functioning and that ML/TF breaches or incidents are identifiable and can be managed if they happen.

Oversight of the AML/CTF program by boards and senior management may result in:

• identification of ML/TF risks associated with your customer types, types of services, delivery methods, and foreign jurisdictions dealt with: the AUSTRAC-produced Self Assessment Questionnaire (SAQ) is a free resource designed to help businesses work out how they are going to comply with their obligations under the AML/CTF Act

• developing and implementing AML/CTF procedures relevant to the nature, size and complexity of your business and the ML/TF risks it may reasonably face
• ensuring sufficient resourcing, both people and funds, to enable the AML/CTF program
• reviewing feedback from AUSTRAC and independent AML/CTF reviews
• reviewing results of audits, checklists, training evaluations, and operational observations of staff performance management relating to following AML/CTF
• managing AML/CTF process improvements
• meeting AUSTRAC's expectations.