AML/CTF Programs

You must implement policies and procedures, systems and controls that detail your how you will identify, mitigate and manage the Risks that your business may reasonably face. These policies must include:

• procedures for an independent evaluation of your AML/CTF Program to be conducted;
• processes to ensure you submit International Funds Transfer Reports (IFTIs), Threshold Transaction Reports (TTRs), Suspicious Matter Reports (SMRs) and other required reports to AUSTRAC within specified timeframes;
• an explanation of the training your personnel will undertake on an ongoing basis in relation to the Risks your business may face;
• a clear delegation of responsibilities of your Governing Body, Senior Managers and AML/CTF Compliance Officer, including the appointment of an AML/CTF Compliance Officer who meets the required standards;
• procedures to screen personnel;
• a Customer Risk Assessment, which enables you to assess the Risk applicable to each customer and categorise their Risk level;
• initial CDD procedures, including:
  • the KYC information you will collect for customers who are classified in each Risk category;
  • processes for verifying KYC information; and
  • the collection of enhanced KYC information;
• ongoing CDD processes, which include:
  • systems and controls to ensure information about customers is kept up to date, and when to collect and verify further KYC information;
  • A risk based transaction monitoring program; and
  • the collection of enhanced KYC information; and
• procedures for the AML/CTF Program to be managed and approved by Senior Managers.