If you score 10+ you are in good shape. 6–9 and you have meaningful work left. Below 6 and you should engage a provider this month.
The 12 questions
- Have you mapped which of your services are designated under the Act?
- Have you completed a written business risk assessment?
- Do you have a Part A program signed by a named compliance officer?
- Do you have a Part B program covering individual and non-individual CDD?
- Have you enrolled (or scheduled enrolment) with AUSTRAC?
- Do you have an electronic ID verification tool selected and configured?
- Do you have sanctions/PEP screening configured for new and existing customers?
- Have all relevant staff completed AML training in the last 12 months?
- Do you have a documented SMR/TTR escalation path?
- Have you scheduled or completed an independent review?
- Are you keeping records in a system that can be exported on demand?
- Has senior management or the board reviewed the program in the last 12 months?