Aml Ctf Compliance Checklist

1

Confirm Your Scope

Determine whether your firm's services are captured under Tranche 2 obligations

Identify all services your firm provides
Map services against the designated services list in the AML/CTF Act
Confirm whether you provide accounting, legal, conveyancing or real estate services to clients
Identify any high-risk service categories (trust & company formation, property transactions, asset management)
Document scope determination with written rationale
Seek legal advice if scope is unclear

Scope Decision Table

Service Type	Captured?	Obligation Level	Action
Accounting — tax & audit	Yes	Full program required	Proceed to Steps 2–9
Legal — conveyancing	Yes	Full program required	Proceed to Steps 2–9
Legal — general advisory	Likely	Seek legal advice	Confirm scope first
Real estate — sales & leasing	Yes	Full program required	Proceed to Steps 2–9
Financial planning (AFSL)	Likely existing	Check current AUSTRAC enrolment	Review existing program

Completed by

Date

Sign-off

2

Decide Your Service Strategy

Choose how your firm will manage its AML/CTF obligations — build, buy, or outsource

Assess internal capability to build and maintain an AML program
Review available AML/CTF compliance software options (e.g. Signum Verify)
Consider outsourcing program management to an AML consultant
Determine budget for compliance infrastructure
Document decision and rationale

Strategy Options

Strategy	Best For	Cost Indicator	Risk Level
Build in-house	Large firms with dedicated compliance staff	High upfront	Medium — requires expertise
SaaS platform (e.g. Signum Verify)	Most small-to-mid firms	Monthly subscription	Low — guided workflow
Outsource to consultant	Firms needing full setup assistance	Project fee + ongoing	Low — expert oversight
Hybrid (SaaS + consultant)	Firms wanting best of both	Moderate	Very low

Completed by

Date

Sign-off

3

Enrol with AUSTRAC

Register your firm as a reporting entity before the enrolment deadline

Access AUSTRAC Online portal (austrac.gov.au)
Create or verify your AUSTRAC Online account
Complete enrolment form with firm details (ABN, entity type, service types)
Confirm enrolment confirmation email received
Record your AUSTRAC reporting entity number
Note: Enrolment opens 31 March 2026; deadline aligns with 1 July 2026

Key Enrolment Details

Item	Detail	Status
Enrolment portal opens	31 March 2026	Noted
AUSTRAC reporting entity number	Record here: ____________	Obtained
Entity ABN	Record here: ____________	Confirmed
Designated services enrolled	List services: ____________	Completed

Completed by

Date

Sign-off

4

Appoint a Compliance Officer

Nominate a senior person responsible for your AML/CTF program

Identify a senior responsible person (must be a partner/director for most firms)
Confirm the appointee understands their obligations
Document the appointment in writing (board resolution or signed letter)
Provide the appointee with access to AUSTRAC Online
Ensure the Compliance Officer has adequate time and authority to fulfil their role
Consider engaging an external AML consultant to support the appointed officer

Appointment Record

Field	Details
Compliance Officer Name
Title / Role
Date of Appointment
Documented in
AUSTRAC Online Access	Granted

Completed by

Date

Sign-off

5

Build Your AML/CTF Program

Develop a risk-based program that addresses your firm's specific ML/TF risks

Conduct a business-wide ML/TF risk assessment
Document your firm's risk appetite and tolerance
Develop Part A: identification & risk assessment procedures
Develop Part B: employee due diligence
Develop Part C (if applicable): agent obligations
Develop Part D: AML/CTF risk awareness training
Document the program in written form
Have program reviewed by a qualified AML specialist
Obtain sign-off from the Compliance Officer

Program Components

Component	Required For	Status
ML/TF Risk Assessment	All reporting entities	Complete
Part A — CDD procedures	All reporting entities	Complete
Part B — Employee due diligence	All reporting entities	Complete
Part C — Agent obligations	If using agents/contractors	N/A or Complete
Part D — AML training	All reporting entities	Complete
Compliance Officer sign-off	All reporting entities	Obtained

Completed by

Date

Sign-off

6

Design CDD Procedures

Establish client due diligence processes for individuals, companies, trusts and other entities

Define standard CDD requirements for each client type (individual, company, trust, SMSF)
Define Enhanced Due Diligence (EDD) triggers and procedures
Establish procedures for identifying beneficial owners
Define PEP (Politically Exposed Person) screening procedures
Set up sanctions screening capability (DFAT, OFAC, UN)
Define ongoing monitoring obligations and review frequency
Implement a record-keeping system for all CDD records (7-year minimum retention)

CDD Requirements by Client Type

Client Type	Standard CDD	EDD Trigger	Beneficial Owner
Individual	Photo ID + address verification	High-risk country, PEP, unusual activity	N/A
Company (Pty Ltd)	ASIC extract, director IDs	Complex structure, foreign-controlled	All >25% shareholders
Trust	Trust deed, trustee ID, settlor details	Discretionary trust, foreign trustee	Beneficiaries >25%
SMSF	ATO confirmation, trustee IDs	Related party transactions	All members
Partnership	Partnership agreement, partner IDs	Silent partners, foreign interests	All partners >25%

Completed by

Date

Sign-off

7

Train Your Staff

Ensure all relevant staff understand their AML/CTF obligations

Identify all staff with client-facing or compliance responsibilities
Develop AML/CTF awareness training materials
Conduct initial training for all relevant staff
Record training completion for each staff member
Schedule annual refresher training
Train staff on how to use your compliance software/workflow
Brief all staff on reporting obligations (SMRs, TTRs)

Training Register

Staff Member	Role	Initial Training Date	Refresher Due	Completed

Completed by

Date

Sign-off

8

Test and Review

Verify that your program works in practice and meets AUSTRAC's requirements

Run a test CDD process on a sample client (individual and company)
Verify that evidence packs can be generated and are AUSTRAC-ready
Test sanctions/PEP screening is functioning correctly
Simulate an EDD scenario and document the outcome
Have an independent reviewer (internal or external) audit the program
Document any gaps found and the remediation actions taken
Confirm the program is ready for 1 July 2026

Testing Outcomes

Test Area	Test Date	Result	Gap/Action	Resolved
Individual CDD workflow
Company CDD workflow
Sanctions screening
Evidence pack generation
EDD scenario

Completed by

Date

Sign-off

9

Document Everything

Maintain auditable records that can be produced on request by AUSTRAC or your professional body

Confirm all CDD records are stored with 7-year minimum retention
Verify records are retrievable within 3 business days
Maintain a register of all Suspicious Matter Reports (SMRs) submitted
Maintain records of all Threshold Transaction Reports (TTRs) filed
Keep a log of all program reviews and audits
Keep training records for all staff for minimum 7 years
Document any tipping-off precautions taken
Ensure the AML/CTF program document is version-controlled and dated

Record-Keeping Summary

Record Type	Minimum Retention	Stored In	Retrievable
CDD / KYC records	7 years from end of relationship
Transaction records	7 years
SMR records	7 years
TTR records	7 years
Staff training records	7 years
Program review records	7 years

Final Program Sign-Off

Declaration	Name	Title	Date	Signature
AML/CTF Program approved
AUSTRAC enrolment confirmed
Program ready for 1 July 2026

AML/CTF Program Readiness Checklist

Confirm Your Scope

Scope Decision Table

Decide Your Service Strategy

Strategy Options

Enrol with AUSTRAC

Key Enrolment Details

Appoint a Compliance Officer

Appointment Record

Build Your AML/CTF Program

Program Components

Design CDD Procedures

CDD Requirements by Client Type

Train Your Staff

Training Register

Test and Review

Testing Outcomes

Document Everything

Record-Keeping Summary

Final Program Sign-Off