Reporting Entities who only provide designated services outlined in item 54 of table 1 in s 6 of the AML/CTF Act are subject to modified AML/CTF obligations.
Item 54 service providers include AFSL holders who arrange for a person (their customer) to receive a designated service. For example, if you do not issue financial products, but arrange for your clients to acquire a financial product from another Reporting Entity, you will be an item 54 service provider. This category commonly includes financial advisers who arrange for their clients to receive designated services from another Reporting Entity.
Exemptions for item 54 service providers
An item 54 service provider is not required to comply with the following requirements:
- lodge an Annual Compliance Report with AUSTRAC;
- conduct an independent evaluation of your AML/CTF Program;
- appoint an AML/CTF Compliance Officer;
- implement employee due diligence procedures;
- conduct employee training; and
- conduct ongoing customer due diligence.
Sophie Grace can provide an AML/CTF Program which can be tailored to your specific needs to ensure that you comply with the obligations under the AML/CTF Act and Rules. We have three different options available to suit your business and finance needs.
Template Documents
You can purchase template documents from our online shop. The template is an instant download and includes prompts to help you tailor the document yourself.
Compliance Portal
Sign up to the Compliance Portal and receive the template AML/CTF Program Package, and obtain access to updated documents in light of any updates we make to the documents as new guidance or amended legislation is released until 31 March 2026.
Tailored Documents
Sophie Grace can assist you to prepare the AML/CTF Program package based on your business’ specific requirements. Contact us to discuss further.
What should you include in your AML/CTF Program?
Your AML/CTF Program must include the following:
Risk Assessment
All Reporting Entities must conduct a Business Risk Assessment, which identifies and assesses the Risks your business may reasonably face. The Risk Assessment should include consideration of:
- The designated services you provide and any new designated services, before they are introduced to the market
- The types of customers you deal with
- Your delivery channels, including
- new methods of delivering a designated service, before they are adopted
- new or developing technologies used to provide designated services, before they are adopted
- the jurisdictions you deal with when providing designated services
- changes in the nature of the business relationship, control structure or beneficial ownership of your customers
Reporting Entities should consider data from a variety of sources when conducting their Business Risk Assessment, including:
- Data on your products or services
- Customer data
- Internal feedback
- Reports from industry bodies
- AUSTRAC guidance
- Other reports from regulators
Important
If you are an item 54 service provider and also provide another designated service (that is in addition to arranging for a person to receive a designated service from another Reporting Entity), you will not be able to rely on the exemptions for item 54 service providers and must adhere to all relevant AML/CTF obligations.
How can Sophie Grace help?
Sophie Grace can provide you with an AML/CTF Program and can assist you to tailor it to your business’ needs. We have three different options available to suit your business and finance needs.
Template Documents
You can purchase template documents from our online shop. The template is an instant download and includes prompts to help you tailor the document yourself.
Compliance Portal
Sign up to the Compliance Portal and receive the template AML/CTF Program Package, and obtain access to updated documents in light of any updates we make to the documents as new guidance or amended legislation is released until 31 March 2026.
Tailored Documents
Sophie Grace can assist you to prepare the AML/CTF Program package based on your business’ specific requirements. Contact us to discuss further.