Your obligations

Enrol and register with us

If you provide a designated service with a geographical link to Australia you must enrol. 

If you’re a remittance service provider or virtual asset service provider, you need to both enrol and apply for registration. 

Learn more about:

• enrolling with us
• registering with us as a remittance or virtual asset service provider

Reporting groups

If you want to share the costs of compliance with other businesses and fit within the framework established by the Act and Rules, you may be able to do so within a reporting group. Entities in a reporting group share some or all risk management and compliance arrangements. This includes those set out in a group AML/CTF program established by a lead entity of the group. 

Obligations apply differently to foreign branches and subsidiaries.

Learn more about reporting groups, and how the laws apply to foreign branches and subsidiaries. 

Establish your governance framework

Strong governance and oversight help protect your business from criminal exploitation and support a culture of AML/CTF compliance.

Your AML/CTF governance structure must clearly identify 3 roles:

• Governing body: has primary responsibility for your governance and executive decisions. They oversee compliance at the highest level.
• Senior manager or managers: approves AML/CTF programs and AML/CTF compliance decisions.
• AML/CTF compliance officer: manages day-to-day AML/CTF compliance and makes sure policies and procedures are implemented.

These roles are usually held by different people, but in smaller businesses, one person may conduct multiple governance responsibilities.

Learn more about governance.

Develop and maintain an AML/CTF program 

An AML/CTF program protects your business from criminal exploitation through money laundering, terrorism financing and proliferation financing. It helps you meet your obligations and contributes to a safer Australian financial system. 

Your program must contain both:

• A risk assessment: you must identify and assess your money laundering, terrorism financing and proliferation financing risks (we refer to these as ML/TF risks).
• AML/CTF policies: you must develop and maintain appropriate policies, procedures, systems and controls to manage and mitigate your ML/TF risks and comply with your obligations. 

Learn more about an AML/CTF program.

Get your personnel ready

Preparing your personnel is critical to help you meet your AML/CTF obligations. This includes making sure:

• they’re fit to perform their roles
• they understand their obligations
• your business has strong governance and oversight in place.

Personnel due diligence and training ensure the people performing AML/CTF functions in your business have the right skills, knowledge and integrity to meet your obligations and manage risk.

We expect your business to:

• conduct personnel due diligence: assess the skills, knowledge, expertise and integrity of personnel you employ or engage to conduct AML/CTF functions
• provide AML/CTF training: make sure personnel understand your AML/CTF obligations and know how to follow your policies, procedures and systems. This is so they can identify, manage and mitigate ML/TF risks.

Learn more about personnel due diligence and training.

Conduct customer due diligence

Customer due diligence (CDD) helps you understand who your customers are and the ML/TF risks they may bring to your business. CDD is separated into initial CDD and ongoing CDD. 

The level of information you collect and verify to complete CDD will depend on the ML/TF risk profile of the customer. 

You must apply enhanced CDD in high-risk scenarios. You may be able to apply simplified CDD in low-risk scenarios. 

Learn more about customer due diligence.

Report certain transactions and suspicious activity

Reporting certain transactions and suspicious activities maintains the integrity of the financial system and helps law enforcement to combat crime. 

The types of reports you may need to submit to us include: 

• suspicious matter reports (SMR): if you suspect a person isn’t who they claim to be, or you have information relevant to criminal activity
• threshold transaction reports (TTR): for any transaction involving physical currency (cash) of $10,000 or more
• international funds transfer reports (IFTI): for instructions to transfer funds into or out of Australia
• cross-border movement reports (CBM): if you move physical currency (cash) and other monetary instruments of $10,000 or more into or out of Australia
• compliance reports: an annual report about how you met your obligations the previous calendar year. 

Learn more about reporting.

Legal professional privilege

The Act contains protections for information or documents that are subject to legal professional privilege (LPP).

The Act doesn’t affect the right of a person to refuse to give information (including by answering a question) or produce a document. This applies if the information or document would be privileged from being given or produced on the grounds of LPP. 

Learn more about legal professional privilege. 

Make and keep records

Record keeping involves creating full and accurate records along with securely storing and managing them. Proper record keeping involves:

• creating accurate and complete records
• keeping records for a specific period, usually 7 years.

The AML/CTF records you must keep are:

• AML/CTF program records
• CDD records
• transaction records related to a designated service.

These records provide evidence of your due diligence, risk management practices and compliance with AML/CTF obligations. 

Learn more about record keeping.

Related pages

• Check if you're regulated and need to enrol
• Combating money laundering, terrorism financing and proliferation financing
• Risks and indicators of suspicious activity