Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Reporting entities have a variety of obligations which need to be documented and adhered to in order to ensure you are compliant.  We can assist you to meet the requirements that your business has by providing relevant and tailored advice.

Businesses who are Reporting Entities under the AML/CTF Act must do a variety of things to ensure they meeting all the elements required by AUSTRAC and the law.

Under the AML/CTF Act, most Reporting Entities have the following obligations:

  • Enrol your business with AUSTRAC as a Reporting Entity and complete the business profile form;
  • Submit an annual Compliance Report to AUSTRAC;
  • Adopt and maintain a written AML/CTF Program that includes procedures to detect, deter, manage and mitigate money laundering and the financing of terrorism.  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; and
    • Store all relevant records.
    • Develop and maintain an Ongoing Customer Due Diligence (OCDD) processes, which include:
      • The collection and verification of further ‘Know Your Customer’ (KYC) information including details of beneficiaries in specified situations;
      • A transaction monitoring program; and
      • An enhanced customer due diligence (CDD) program.
      • Report all suspicious transactions (Suspicious Matter Reports (SMRs)), International Funds Transfer Instructions (IFTIs) and threshold transactions (Threshold Transaction Reports (TTRs)) to AUSTRAC;
      • Develop a system to monitor compliance with your AML/CTF Program including regular external audits.

Published - AML:CTF - Flow Chart


Sophie Grace is able to provide ongoing compliance support to Reporting Entities in order to ensure your AML/CTF obligations are met.  If you would like further information of assistance, please contact Sophie Grace directly.