What is an AML/CTF Program?
Anti-Money Laundering and Counter-Terrorism Financing Program
An AML/CTF Program is the written compliance program every Australian reporting entity must adopt and maintain. It has two parts. Part A covers the general program: a documented money-laundering and terrorism-financing risk assessment, governance arrangements, the AML compliance officer, staff training, ongoing monitoring strategy, board oversight, and independent review at appropriate intervals. Part B is the applicable customer identification program — the CDD/KYC procedures, including for beneficial owners and PEPs. The program must be tailored to your business, kept current, board-approved, and capable of producing on-demand audit evidence. It's the document AUSTRAC asks for first in a supervisory engagement, and the artifact courts evaluate when assessing whether a contravention was systemic.
What AML/CTF Program means in practice since 1 July 2026
Since 1 July 2026, no Tranche 2 firm can lawfully provide a designated service without an adopted Part A and Part B program. Template-only programs aren't sufficient — AUSTRAC expects evidence the program reflects your actual customers, services and risks. This is the single most important deliverable — one every captured firm should have had in place at 1 July 2026 commencement and should still have today.
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