A practical guide to building an AUSTRAC-compliant AML/CTF program for Tranche 2 regulated businesses.
What Must Your AML/CTF Program Include?
Under the AML/CTF Act your program must be in writing and must include the following components.
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Risk assessment Document ML/TF risks for your designated services, clients, delivery channels and countries. Rate each risk as Low, Medium or High. AUSTRAC provides sector-specific starter kits.
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Policy document Written policies covering personnel roles, initial and ongoing CDD, escalation procedures, reporting obligations and record keeping.
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Process document Step-by-step standard operating procedures for carrying out each aspect of your AML/CTF obligations.
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Compliance officer appointment A designated AML/CTF compliance officer responsible for overseeing the program. Must be notified to AUSTRAC within 14 days of appointment.
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Staff training program Initial and ongoing training for all personnel performing AML/CTF functions. Training records must be kept.
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CDD procedures Documented procedures for initial CDD, ongoing CDD, enhanced CDD and pre-commencement customer due diligence.
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Reporting procedures Procedures for identifying and submitting suspicious matter reports, threshold transaction reports and cross-border movement reports.
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Independent evaluation Your program must be independently evaluated at least every 3 years.