Annual AML/CTF program review checklist (AU)
The AML/CTF regime is risk-based and rigorous — AUSTRAC expects an annual independent program review and a living risk assessment. This checklist covers the 12 program components a mature AML/CTF program should refresh each year.
This is a 12-step annual AML/CTF program review checklist for Australian reporting entities. It covers the Part A (risk-based) and Part B (KYC) program components, ML/TF risk assessment, ECDD triggers, AUSTRAC reporting, board oversight, and readiness for Tranche 2 DNFBP obligations. Use it as an annual program review.
The checklist
ML/TF risk assessment refresh
Refresh the ML/TF risk assessment covering customers, products, channels, and jurisdictions. Consider AUSTRAC sector risk products.
Board and senior management oversight
Confirm board and senior management approval of the AML/CTF program and risk assessment. Confirm the AMLCO is adequately resourced.
Part A framework review
Review Part A framework — risk management, employee due diligence, training, independent review scheduling.
Part B — customer identification
Review KYC procedures — risk-based tiers, beneficial ownership verification, PEP and sanctions screening.
Enhanced customer due diligence
Audit ECDD triggers and the evidence requirements — high-risk customers, PEPs, unusual activity.
Ongoing customer due diligence
Confirm OCDD — transaction monitoring, periodic KYC refresh, trigger-based reviews.
SMR and TTR reporting
Audit suspicious matter report and threshold transaction report pipelines, timeliness, and quality.
IFTI and cross-border movement reporting
Audit IFTI-E and IFTI-DRA reporting where applicable.
Training completion
Confirm training completion rates — general awareness and role-specific — across staff and contractors.
Independent review
Plan or commission the independent review of Part A. Track remediation of prior independent review findings.
Sanctions and financial crime integration
Confirm alignment between sanctions screening and AML program. Escalate hits through a single workflow.
Tranche 2 readiness
For DNFBPs (lawyers, accountants, real estate, trust and company service providers), scope the Tranche 2 reform transition.
When this checklist applies
Use this checklist annually — ahead of the AUSTRAC compliance report and board AML review. For Tranche 2 entities, use it now to scope readiness before the reforms take effect.
Common pitfalls
- Risk assessment drifting out of date — product and channel risk changes not captured
- ECDD trigger logic buried in procedure — no central visibility
- SMR backlog or quality issues
- Training completion rates below target and not tracked to role
- Independent review findings carried year over year
Run this checklist on a real matter
Quillio runs an AML/CTF gap analysis, refreshes the ML/TF risk assessment, and drafts independent review work papers. See /practice-areas/commercial-lawyers or start a free trial.
This checklist is for authorised reporting entities. Tranche 2 obligations for lawyers, accountants, real estate, and TCSPs are subject to transition rules.
Use this checklist on your matter.
Quillio can run this checklist on a specific NSW conveyancing matter — confirm each item, calculate adjustments, and generate the supporting documents. The free trial requires no credit card.
Start your free trial