Quick Overview of the AML and CTF Program
- What it is: Your documented framework for how you meet AML CTF obligations.
- Why it matters: It is the backbone for a risk based approach, customer due diligence, reporting, training, and review.
- Reform context: AUSTRAC has released reforms guidance and is transitioning the regime towards updated obligations.
What Is an AML and CTF Program?
AUSTRAC defines an AML and CTF program as a document that sets out how a reporting entity meets its AML CTF compliance obligations. AUSTRAC references AML CTF Act 2006 section 83 for this term.
In practice, this is not just a policy. It is your compliance operating system. It should be written so that a manager can run it, staff can follow it, and an auditor can test it.
What an AML and CTF program is designed to do
A strong AML and CTF program answers four practical questions.
Why this matters now for Tranche 2 entities
The AML CTF Amendment Act 2024 expands the regime to certain high risk services provided by lawyers, accountants, trust and company service providers, real estate professionals, and dealers in precious metals and stones.
This is why Tranche 2 businesses must treat the AML and CTF program as a priority deliverable, not a final paperwork step.
AUSTRAC has also published clear transition messaging and dates for reform implementation, including enrolment opening for newly regulated sectors and obligations commencing for Tranche 2 entities in 2026.
This means preparation should start early, especially where your business model is decentralised across offices, partners, or contractors.
What to include in an AML and CTF program
The exact structure varies, but the content needs to be complete and usable.
Governance and oversight
Appointment of accountable owners for AML CTF compliance
Senior management oversight and reporting cadence
Risk appetite statements in plain language
Escalation pathways for suspicious matters
Risk assessment and risk based approach
Customer risk factors and scoring logic
Product or service risks
Delivery channel risks, including remote onboarding
Geographic risks and cross border exposure
Customer due diligence and beneficial ownership
Identification and verification processes
Beneficial ownership identification approach where the customer is not an individual
Enhanced due diligence triggers for higher risk relationships
Ongoing due diligence, including refresh triggers
Monitoring and reporting
How you detect unusual behaviours relevant to your services
How you investigate concerns
How you decide whether suspicion exists
How you maintain reporting records and supporting material
Training and capability
Induction training for new staff
Role based training for higher risk roles
Scenario based training relevant to your sector
Competency checks and refresh cycles
Independent review and continuous improvement
Independent evaluation schedule
File testing approach and quality assurance
Management of findings and remediation
Change management for new services or channels
Examples of how this looks in Tranche 2 sectors
Best practice tips that stand up to AUSTRAC scrutiny
Keep the program aligned to how work is actually done, including who collects documents and who approves risk ratings.
Use plain language procedures, then back them with templates and checklists.
Evidence implementation through training logs, file reviews, monitoring outcomes, and management reporting.
Prepare an implementation plan if transitional gaps are likely, noting AUSTRAC’s expectations around managing risk during transition periods.
Common challenges
Template based documents that do not reflect the firm’s actual services
Overly legal writing that staff cannot apply
Lack of evidence that controls are used consistently
Weak beneficial ownership handling, especially for companies and trusts
Key Takeaways and Final Thoughts
An AML and CTF program is not a compliance checkbox. It is the system that protects your business, your clients, and the integrity of the market. Under the AML CTF Amendment Act 2024 and the reform transition, businesses that invest early in a practical program will reduce regulatory risk and operational disruption.
“Bookmakers sit at a natural convergence point for cash, speed and anonymity. AUSTRAC’s focus reflects the reality that wagering platforms can be misused as value transfer mechanisms if risk controls are not actively applied.”
