About the 2020 compliance report
The information on this page will help you complete the 2020 compliance report.
This report will cover your business activities for the 2020 calendar year.
When your report is due
Your 2020 compliance report must be submitted to AUSTRAC by 31 March 2021.
Note: Last year due to the exceptional circumstances of the COVID-19 pandemic, the deadline for submitting the compliance report was extended to 30 June 2020. This extension no longer applies.
Preview of the 2020 compliance report questions
The questions in the 2020 compliance report are listed in the following tables to help you prepare. Based on feedback from last year, we’ve made changes to some of the questions this year to make it easier for you to complete your report.
An explanation of the bolded terms related to each question can be found under ‘key terms’. Further information can be found by clicking the linked text.
- Designated services during 2020
- Your business
- Managing AML/CTF program
- Assessing your ML/TF risk
- Managing employee risk
- Your customers
- Managing customer risk
- Reporting to AUSTRAC
- AUSTRAC feedback and guidance
Designated services during 2020
Questions |
Key terms |
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Did you offer designated services during all or part of the reporting period (1 January 2020 to 31 December 2020)? (Yes or No) |
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If No (you will only be presented with the Your feedback and Review and submit sections of the form): Are you sure? You have been enrolled as providing designated services during this period.
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Your business
Questions | Key terms |
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Do you have less than 5 employees? (Yes or No) |
Employee A person who is employed full time or part time, or a casual staff member paid under contract or through wages or salary. |
How did you provide designated services in 2020? (Select all that apply)
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IDM Intelligent Deposit Machine, a type of advanced ATM that offers self-service transaction facilities which credits cash and cheque deposits to recipient accounts. Mobile application Is software often called an "App", designed to run on a mobile device, such as a smartphone or tablet. Remittance platform A system that enables funds transfers for remittance purposes. If you are a remittance network provider, whose affiliates conduct transactions using your remittance platforms, you MUST select this option. Self-service gambling terminal A terminal at which customers can credit or withdraw from an account or place a bet or wager. Self-service gambling terminal does NOT include an electronic gaming machine. Additional method(s) Select this option if you provided designated service(s) using methods other than, or in addition to, those that are listed. If you enter more than one 'Additional method', please separate them with a comma. |
Were any of the above delivery methods introduced in 2020? (Yes or No) |
Delivery methods Channels through which your business provides or delivers the designated services. |
Outsourcing |
Outsourcing Entering into an agreement with a third party to undertake aspects of the AML/CTF program on your behalf.
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Did you outsource customer identification? (Yes or No) |
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If yes: Was this function outsourced to multiple providers? Business legal name of provider? Was this function performed outside of Australia? Was this function further outsourced by the service provider? |
Multiple providers Main provider If this AML/CTF compliance function was outsourced to a number of providers, please enter the name of the provider who performed the highest proportion of this function. Provider type If this AML/CTF compliance function was outsourced to a large number of a particular type of provider (e.g. financial advisor, mortgage originator, etc.), please enter the type of provider instead of the business legal name. |
Did you outsource AML/CTF program development? (Yes or No) |
Outsourcing AML/CTF program development includes:
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If yes: Was this function outsourced to multiple providers? Business legal name of provider? Was this function performed outside of Australia? Was this function further outsourced by the service provider? |
Multiple providers Main provider If this AML/CTF compliance function was outsourced to a number of providers, please enter the name of the provider who performed the highest proportion of this function. Provider type If this AML/CTF compliance function was outsourced to a large number of a particular type of provider (e.g. financial advisor, mortgage originator, etc.), please enter the type of provider instead of the business legal name. |
Did you outsource transaction monitoring? (Yes or No) |
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If yes: Was this function outsourced to multiple providers? Business legal name of provider? Was this function performed outside of Australia? Was this function further outsourced by the service provider? |
Multiple providers Main provider If this AML/CTF compliance function was outsourced to a number of providers, please enter the name of the provider who performed the highest proportion of this function. Provider type If this AML/CTF compliance function was outsourced to a large number of a particular type of provider (e.g. financial advisor, mortgage originator, etc.), please enter the type of provider instead of the business legal name. |
Did you outsource transaction reporting? (Yes or No) |
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If yes: Was this function outsourced to multiple providers? Business legal name of provider? Was this function performed outside of Australia? Was this function further outsourced by the service provider? |
Multiple providers Main provider If this AML/CTF compliance function was outsourced to a number of providers, please enter the name of the provider who performed the highest proportion of this function. Provider type If this AML/CTF compliance function was outsourced to a large number of a particular type of provider (e.g. financial advisor, mortgage originator, etc.), please enter the type of provider instead of the business legal name. |
Managing AML/CTF program
Questions |
Key terms |
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Do you have an AML/CTF program? (Yes or No)
If no: |
AML/CTF Program Sole trader or individual If your business operates as a sole trader or an individual, you are still required to have an AML/CTF program. |
Please explain why you do not have an AML/CTF program. |
AML/CTF Program Explain why you do not have an AML/CTF program |
If yes: |
AML/CTF program approval Approved program Approved means adoption of the initial program or approval of changes to your program by your board, senior management or equivalent. Sole trader If your business operates as a sole trader or an individual, then the sole trader or individual will need to approve the program. Governing board If your business does not have a governing board, then your senior management will need to approve the program. |
Was your AML/CTF program approved in 2020? (Yes or No) |
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If yes: |
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If yes: What prompted these changes? (Select all that apply)
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Changes to AML/CTF program The events that prompted changes to the program. These may have occurred outside of the reporting period. Media reports Reports include, but are not limited to, newspaper articles, news websites, social media. Additional reason(s) Select this option if you have reason(s) other than, or in addition to, the reasons that are listed. If you enter more than one 'Additional reason', please separate them with a comma. |
Was Part A of your program independently reviewed in 2020? (Yes or No) |
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If yes:
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Reasons for review The events that prompted this review. These may have occurred outside of the reporting period. Media reports Reports include, but are not limited to, newspaper articles, news websites, social media. Additional reason(s) for review Select this option if you have reason(s) other than, or in addition to, the reasons that are listed. If you enter more than one 'Additional reason', please separate them with a comma. |
How was the independent review conducted? (Internally/ Externally/ Combined/ Service provider type/ Accountant/ Lawyer/ Other) |
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Did you report internally on any of the following matters in 2020? (Yes or No)
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Reporting internally Means informing your board, senior management or equivalent through a recorded notification (e.g. email, written brief, attendance at a minuted meeting). Other matter(s) Select this option if you reported on any matter(s) other than, or in addition to, the matters that are listed. If you enter more than one 'Other matter', please separate them with a comma. |
If yes: (Select all that apply)
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Assessing ML/TF risk
Questions |
Key terms |
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Did you do an ML/TF risk assessment of your business in 2020?(Yes or No) |
ML/TF ML/TF means money laundering and terrorism |
If yes: |
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If yes:
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Media reports Reports include, but are not limited to, newspaper articles, news websites, social media. Additional reason(s) Select this option if you had reason(s) other than, or in addition to, the reasons that are listed. If you enter more than one 'Additional reason', please separate them with a comma. |
Do you have a documented process for conducting a risk assessment? (Yes or No) |
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Managing employee risk
Questions |
Key terms |
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What employee checks do you conduct? (select all that apply)
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Third party providers You have also conducted a check if you use a third party provider for employee due diligence. Select the checks that they undertake on your behalf. Open source searches Information searches using publicly available sources on internet. PEP A PEP is a politically exposed person. Social media review Information searches on social network online platforms. Additional checks Select this option if you conducted checks other than, or in addition to, those that are listed. If you enter more than one 'Additional check', please separate them with a comma. |
Do you assess the ML/TF risk of individual roles in your business? (Yes or No) |
ML/TF ML/TF means money laundering and terrorism financing. |
If yes: |
Employee check ML/TF ML/TF means money laundering and terrorism financing. |
Did you provide AML/CTF training in 2020? (Yes or No) |
AML/CTF training |
If yes:
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AML/CTF training type Additional training type(s) Select this option if you provided training other than, or in addition to, the types that are listed. If you enter more than one 'Additional training', please separate them with a comma |
Did you update your AML/CTF training program in 2020? (Yes or No) |
Updates to AML/CTF training program Includes changes to the content of training, the way in which the training was delivered, who it was delivered to, or how frequently it was delivered. |
If yes: What prompted this update? (select all that apply)
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Media reports Reports include, but are not limited to, newspaper articles, news websites, social media. Additional reason(s) Select this option if you had reason(s) other than, or in addition to, the reasons that are listed. If you enter more than one 'Additional reason', please separate them with a comma. |
Your customers
Questions |
Key terms |
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Customers |
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What are your Customer types? (select all that apply)
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Customer types These are the types of customers that you provide designated services to. |
Customer verification |
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Did you verify the identity of your customers in 2020? Yes/No/Not required |
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If yes:
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Risk assessment |
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How many of your customers are high risk or above? |
High risk customer You are required to assess what you consider to be a high risk customer within your business. This assessment should be set out in your AML/CTF program. Factors that you should take into account include:
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Did you perform Politically Exposed Persons (PEPs) checks in 2020? (Yes or No) |
Politically Exposed Persons (PEPs) Where your business uses a broader PEP definition than that prescribed by the AML/CTF Act, you may choose to answer based on that definition. |
How did you identify PEPs (select all that apply)
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Politically Exposed Persons (PEPs) identification Where your business uses a broader PEP definition than that prescribed by the AML/CTF Act, you may choose to answer based on that definition. Open source searches Information searches using publicly available sources on internet. Commercial database A database of information developed and maintained by a commercial entity and made available to customers. This is the information for which you are likely to pay or subscribe for. Additional method(s) Select this option if you identify PEPs using methods other than, or in addition to, the methods that are listed. If you enter more than one ‘Additional method', please separate them with a comma. |
Managing customer risk
Questions |
Key terms |
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Unusual or potentially suspicious activity |
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Did your staff identify and report any unusual or potentially suspicious activity in 2020? (Yes or No) |
Unusual or potentially suspicious activity Your staff reporting You or your staff may report unusual or potentially suspicious activity by escalating the matter to a specified person or area within your business or by submitting a suspicious matter report (SMR) directly to AUSTRAC. |
If yes:
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Reporting of unusual or suspicious activity You or your staff may report unusual or potentially suspicious activity by escalating the matter to a specified person or area within your business or by submitting a suspicious matter report (SMR) directly to AUSTRAC. Online form A digital form that is accessible and editable online. SMR SMR means suspicious matter report. Additional method(s) Select this option if you report using methods other than, or in addition to, the reporting methods that are listed. If you enter more than one 'Additional method', please separate them with a comma |
Transaction Monitoring Program (TMP) |
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Do you have a TMP in place? (Yes or No) |
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If yes: Did you review TMP rules in 2020? |
Transaction Monitoring Program (TMP) rules Any rules, logic or thresholds that are used to identify unusual or potentially suspicious transaction activity. |
If yes: What prompted you to review your TMP rules? (select all that apply)
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Review of TMP rules High ratio of false-positives A significant proportion of the matters identified through a particular rule or threshold are deemed not to be suspicious. Media reports Reports include, but are not limited to, newspaper articles, news websites, social media. Additional reasons for review Select this option if you had reason(s) other than, or in addition to, those that are listed. If you enter more than one 'Additional reason', please separate them with a comma. |
If response to the question ‘Do you have a TMP in place’ is yes: Did your TMP identify any suspicious customer transactions that required further review in 2020? (Yes or No) |
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If yes: Did you review these matters in any order of priority? (Yes or No) |
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If yes: What factors were given priority? (select all that apply)
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Jurisdiction risk Risk associated with doing business with a customer located in, or transacting through, a foreign country. ML/TF ML/TF means money laundering and terrorism financing. Additional factor(s) Select this option if you had factor(s) other than, or in addition to, those that are listed. If you enter more than one 'additional factor', please separate them with a comma. |
Enhanced Customer Due Diligence (ECDD) |
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Did you conduct ECDD in 2020? (Yes or No) |
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If yes: How did you conduct ECDD?(select all that apply)
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Conducting ECDD Extra information gathered Collection of extra information from the customer or third party sources to clarify already collected KYC or beneficial owner information, or to identify the source of wealth and funds of the customer and beneficial owners. KYC information Know-Your-Customer information. Senior management approval An approval by senior management for continuing the business relationship and the provision of a designated service to the customer. Additional methods Select this option if you used method(s) other than, or in addition to, those that are listed. If you enter more than one 'Additional method', please separate them with a comma. |
If no: Do you have an ECDD program in place? (Yes or No) |
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Reporting to AUSTRAC
Questions |
Key terms |
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Were you required to submit reports to AUSTRAC in 2020? (Yes or No) |
Reports to AUSTRAC Reports include threshold transaction reports (TTR), suspicious matter reports (SMR), international funds transfer instructions (IFTI) and compliance reports. |
If yes: How did you ensure your reports were submitted on time? (select all that apply)
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On time On time means within the timeframes specified in the AML/CTF Act and Rules. Specialised reporting function Select this option if transaction reporting was undertaken by a specific team or person who is not the AML/CTF Compliance Officer. Additional method(s) Select this option if you used method(s) other than, or in addition to, those that are listed. If you enter more than one 'Additional method', please separate them with a comma. |
If yes:
How did you ensure your reports were accurate? (select all that apply)
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Specialised reporting function Select this option if transaction reporting was undertaken by a specific team or person who is not the AML/CTF Compliance Officer. Additional method(s) Select this option if you used method(s) other than, or in addition to, those that are listed. If you enter more than one 'Additional method', please separate them with a comma. |
AUSTRAC feedback and guidance
Questions |
Key terms |
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Did you receive any guidance material or correspondence from AUSTRAC in relation to your business' compliance during 2020? (Yes or No) |
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If yes:
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Response to AUSTRAC feedback ML/TF ML/TF means money laundering and terrorism financing. Additional action(s) Select this option if you took action other than, or in addition to, those that are listed. If you enter more than one 'Additional action', please separate them with a comma. |
The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.