AML/CTF Programs

An AUSTRAC Reporting Entity is required by the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 to adopt and maintain procedural documentation to address the obligations imposed by the Act. The AML/CTF Program must comply with the AML/CTF Rules.

Sophie Grace can provide an AML/CTF Program tailored to your specific needs to ensure that you comply with the obligations under the AML/CTF Act and Rules.

What should you include in your AML/CTF Program?

The Program must include the following:

• Procedures to identify, mitigate and manage the risks that the provision of a designated service may involve; and
• Set out the applicable KYC processes;
• Submit International Funds Transfer Reports (IFTIs), Threshold Transaction Reports (TTRs), Suspicious Matter Reports (SMRs) and other required reports to AUSTRAC within specified timeframes;
• Develop procedures to screen employees before they are employed and/or when they are promoted (employee due diligence program);
• Appoint an AML/CTF Compliance Officer;
• Train your staff and representatives on an ongoing basis in AML/CTF risk awareness;
• Store all relevant records;
• Develop a system to monitor compliance with your AML/CTF Program including regular external compliance reviews; and
• Develop and maintain an Ongoing Customer Due Diligence (OCDD) processes, which includes:
  • The collection and verification of further ‘Know Your Customer’ (KYC) information including details of beneficiaries in specified situations;
  • A transaction monitoring program;
  • An enhanced customer due diligence (CDD) program; and
  • Report all suspicious transactions (Suspicious Matter Reports (SMRs)), International Funds Transfer Instructions (IFTIs) and threshold transactions (Threshold Transaction Reports (TTRs)) to AUSTRAC.

If you provide remittance services or operate as a digital currency exchange provider, you will be required to have an AML/CTF Program in place in order to finalise your registration with AUSTRAC.

Sophie Grace can provide you with an AML/CTF Program tailored to your business’ needs. Alternatively, you can purchase a template document from our online shop.