AML/CTF Program

Part A must include processes and procedures to identify, mitigate and manage ML/TF risks.

Part B focuses on the applicable customer identification procedures (ACIP).

Programs integrate these into operational elements, including customer due diligence, ongoing monitoring, AUSTRAC reporting, employee training schedules, and independent reviews every three years for tranche 2 entities.

Senior management or board approves the program, the governing body oversees it, and an AML/CTF compliance officer manages day-to-day operations and AUSTRAC communication.