Set-up (once)
- Confirmed which designated services we provide.
- Enrolled with AUSTRAC within 28 days of first providing them.
- Appointed an AML/CTF compliance officer at management level.
- Written and adopted an AML/CTF program with a risk assessment and policies.
- Trained every client-facing staff member and recorded it.
- Set up a client register with identification, risk rating and review date fields.
Every new client
- Identified and verified the client with a reliable, independent document before the service.
- Identified and verified beneficial owners of any company, trust or partnership.
- Recorded the purpose of the relationship.
- Rated the risk; applied enhanced due diligence if high.
- Set the next review date.
Ongoing
- Reviewed client files when due (high 6 months, medium 12, low 24).
- Reported any suspicious matter within 3 business days.
- Reported any cash transaction of AU$10,000 or more within 10 business days.
- Reviewed the program yearly and when services or law changed.
- Retrained staff yearly.
Every year
- Lodged the annual compliance report with AUSTRAC.
- Checked that records are complete and retrievable for 7 years.
Questions people ask
- How long does the set-up take?
- With a tool that generates the program from a questionnaire, an afternoon. Writing the program from a blank page takes days.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.