Law firm AML/CTF program review checklist
Law firms from 1 July 2026 must have an AML/CTF program under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. This checklist is for firms reviewing their program annually or on material change.
This is a 12-step checklist for reviewing a law firm AML/CTF program. It covers risk assessment, Part A, Part B, governance, and audit.
The checklist
Review ML/TF risk assessment
Review the firm's ML/TF risk assessment covering clients, services, geography, and channels.
Review Part A program
Review Part A covering systems, controls, and governance.
Review Part B CDD procedures
Review Part B covering customer due diligence procedures.
Review board oversight
Confirm board/partnership oversight of the program.
Confirm AML compliance officer
Confirm an appointed AML compliance officer with appropriate seniority.
Review staff training
Check training records for all relevant staff.
Review employee due diligence
Review employee due diligence and vetting processes.
Review suspicious matter reporting
Review SMR process and historical reports to AUSTRAC.
Review record keeping
Check record keeping procedures for 7 year retention.
Review independent review
Confirm an independent review has been conducted at the required interval.
Identify program gaps
Identify gaps and recommend remediation actions.
Update program
Update and approve the revised program with partnership or board sign-off.
When this checklist applies
Use annually or when the firm's services, clients, or risk profile materially change.
Common pitfalls
- Risk assessment not refreshed when services change
- Board oversight not documented
- Training records incomplete
- Independent review overdue
- SMR process not tested
Run this checklist on a real matter
Quillio can review a law firm AML program and produce a gap analysis. See /practice-areas/firm-management or start a free trial.
General guidance for AML program reviews. Apply current AML/CTF Rules and AUSTRAC guidance.
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.
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