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AML/CTF Checklist

AML/CTF Compliance Checklist (Australia)

A complete, AUSTRAC‑aligned checklist for Tranche 2 businesses — covering AML/CTF Program, ML/TF risk assessment, CDD/ECDD, SMR, training and record‑keeping.

1. AML/CTF Program (Part A & Part B)

Your AML/CTF Program must be written, approved, implemented and regularly reviewed.

  • Documented Part A (governance, controls, oversight)
  • Documented Part B (CDD, ECDD, ongoing monitoring)
  • Senior management approval
  • Independent review process in place
  • AML/CTF compliance officer appointed

2. ML/TF Risk Assessment

AUSTRAC requires a documented ML/TF risk assessment covering customers, services, delivery channels and geography.

  • Inherent risk assessment completed
  • Controls documented and mapped to risks
  • Residual risk ratings assigned
  • Risk assessment reviewed annually
  • Customer risk rating methodology defined

3. Customer Due Diligence (CDD)

CDD must be completed before providing a designated service.

  • Identity verification procedures documented
  • Beneficial ownership checks performed
  • Ongoing monitoring process in place
  • CDD records stored for 7 years
  • CDD triggers defined for re‑verification

4. Enhanced Customer Due Diligence (ECDD)

ECDD is required for higher‑risk customers, transactions or scenarios.

  • ECDD triggers defined (PEPs, high‑risk jurisdictions, unusual activity)
  • Additional verification steps documented
  • Senior management approval for high‑risk cases
  • ECDD decisions recorded with justification

5. Suspicious Matter Reporting (SMR)

SMRs must be submitted to AUSTRAC within required timeframes.

  • SMR red flags documented
  • Internal escalation process defined
  • SMR logging template in use
  • SMR decisions recorded (including 'no SMR' decisions)
  • Staff trained on SMR obligations

6. Training & Awareness

Staff must be trained on AML/CTF obligations relevant to their role.

  • Training program documented
  • Training delivered at onboarding
  • Annual refresher training completed
  • Training records stored for 7 years

7. Record‑Keeping

AUSTRAC requires 7‑year retention of AML/CTF records.

  • CDD/ECDD records stored securely
  • SMR logs retained
  • Risk assessment versions archived
  • AML/CTF Program versions archived
  • Training records retained

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