Step 1: Establish your governance framework (Reform)

Learn about the importance of governance and oversight for your anti-money laundering and counter-terrorism financing (AML/CTF) program.

There are 3 roles in the AML/CTF governance structure: 

  • governing body: the person or group primarily responsible for governance and making executive-level decisions
  • senior manager or managers: who approves the AML/CTF program and makes key decisions
  • AML/CTF Compliance officer: who manages daily compliance, reports to the governing body and makes sure your AML/CTF policies are followed.

Typically, different people hold the roles. However, in small businesses, one person may hold multiple or all 3 governance roles.

This guidance sets out how we interpret the Act, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened. 

The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.

This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.

Last updated: 16 Oct 2025
Page ID: 1386

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