Your AML/CTF program (Reform)
You must develop, maintain and comply with an anti-money laundering and counter-terrorism financing (AML/CTF) program tailored to your business.
On this page
- Program overview
- AML/CTF program obligations
- Risk-based approach
- Obligations overview
- Next step
- Related pages
On this page you’ll learn about the steps you need to take to develop your AML/CTF program. This will help you implement a risk-based approach and meet your obligations.
Program overview
Your AML/CTF program must include both your:
- money laundering and terrorism financing (ML/TF) risk assessment. This identifies and assesses your money laundering, terrorism financing and proliferation financing risks. We refer to these as ML/TF risks. It’s the first step to develop your program and shapes the AML/CTF policies that protect your business
- AML/CTF policies. These detail the policies, procedures, systems and controls you’ll use to manage and mitigate your ML/TF risks. They ensure you comply with your AML/CTF obligations.
AML/CTF program obligations
This section refers to the Act sections 26C, 26D, 26E, 26F, 26G, 26U, 107, 111, 114 and 116.
Your AML/CTF program must be:
- in place before you start providing a designated service
- clearly documented in writing
- approved by a senior manager
- complied with.
You must also:
- review and update your program to make sure it remains current as circumstances change
- conduct periodic independent evaluations of your program
- make and keep records relating to the designated services you provide and your AML/CTF obligations.
The following must also be appropriate to the nature, size and complexity of your business:
- the steps you take to complete your risk assessment
- your AML/CTF policies
- internal reviews of your risk assessment
- the frequency and conduct of independent evaluations of your AML/CTF program.
Risk-based approach
Different reporting entities face different ML/TF risks. This is why an effective program must be ‘risk-based’ and designed to address the specific risks of your business along with its needs and characteristics.
Obligations overview
Below are your general obligations and an overview of the steps you must take to meet your obligations.
| Obligation | Steps |
|---|---|
| Establish your governance framework |
|
| Conduct an ML/TF risk assessment |
|
| Develop AML/CTF policies |
|
| Document and approve your AML/CTF program |
|
| Comply with your program |
|
| Review and update your AML/CTF program |
|
| Independent evaluation |
|
Next step
Go to Step 1: Establish your governance framework.
Related pages
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.