Program template
AML/CTF program template for accountants, bookkeepers, BAS agents
A sample AML/CTF program for a small Australian firm: purpose, designated services, risk assessment, compliance officer, customer due diligence, reporting, record keeping, training and review. See the full document and print it.
The sample below is for a fictional four-person practice. It has the ten sections AUSTRAC looks for. Names and numbers are made up.
See the sample program
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Questions people ask
- What must an AML/CTF program contain?
- Two parts: a money laundering and terrorism financing risk assessment of your firm (clients, services, delivery channels, jurisdictions) and the policies and procedures you use to manage that risk: customer due diligence, ongoing monitoring, reporting, record keeping, staff training and independent review. It must be approved by senior management and reviewed regularly.
- Can I just use this template as my program?
- Use it as a starting point. The sample is built for a typical small practice; your program must reflect your own services, clients and risks. Adopt it only after reading it and changing what does not fit. The software generates one from your own answers in about ten minutes.
- How often must the program be reviewed?
- Whenever your services, client base or the law changes, and in any case regularly; a yearly review is common practice and is what this template sets. The Act also requires an independent evaluation of the program at intervals.
Set up your program in the first ten minutes.
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