AML/CTF Program Australia

What Is an AML/CTF Program?

An AML/CTF program is a documented framework that sets out how your business identifies, manages and mitigates the risk of money laundering and terrorism financing. Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, every reporting entity must have one in place before providing designated services.

A compliant AML/CTF program must include:

• A risk assessment identifying the ML/TF risks specific to your business, customers, products, services, delivery channels and jurisdictions
• Policies and procedures that address those risks
• A customer due diligence (CDD) and Know Your Customer (KYC) framework
• Ongoing transaction monitoring
• Suspicious Matter Reporting (SMR) processes
• Employee awareness training
• An appointed AML/CTF Compliance Officer
• A process for regular review and independent audit

Who Needs an AML/CTF Program in Australia?

Any business that provides a designated service under the AML/CTF Act is a reporting entity and must have a compliant program.

This includes:

• Financial services providers
• Remittance dealers
• Digital currency exchange providers
• Lawyers and law firms (from 1 July 2026)
• Accountants and bookkeepers (from 1 July 2026)
• Real estate agents (from 1 July 2026)
• Conveyancers (from 1 July 2026)
• High-value dealers in precious metals and stones (from 1 July 2026)
• Trust and company service providers (from 1 July 2026)

If your business is captured under Australia’s Tranche 2 reforms, you are required to have an AML/CTF program operational by 1 July 2026. AUSTRAC enrolment opens from 31 March 2026.

Not sure if these obligations apply to your business? Book a free consultation, and we’ll confirm your obligations.

What Does a Tranche 2 AML/CTF Program Require?

The AML/CTF Amendment Act 2024 extends the regime to thousands of professional services businesses that previously had no formal AML obligations. If your business is newly covered by the Tranche 2 entity, your program must be in place and operational from 1 July 2026.

At a minimum, your program must cover:

• A written AML/CTF risk assessment specific to your business
• Policies and procedures governing how you manage ML/TF risk
• Customer due diligence processes, including identity verification, beneficial ownership checks and PEP and sanctions screening
• Ongoing monitoring of customer activity and transactions
• Suspicious matter reporting procedures
• Record-keeping for a minimum of seven years
• An AML/CTF Compliance Officer at management level
• AML/CTF training for relevant staff
• Regular review and independent audit of your program

Non-compliance carries significant civil penalties. Starting early gives your business the time to implement properly and avoid last-minute compliance risk.

How One AML Builds Your AML/CTF Program

We work with you from the ground up to build a program that is tailored to your business, practical to operate and fully compliant with AUSTRAC requirements. We do not produce generic templates. Every program we deliver reflects your specific risk profile, industry, customer base and business structure.

Our process includes:

1. Risk Assessment: We conduct a thorough ML/TF risk assessment covering your customers, products and services, delivery channels and geographic exposures. This forms the foundation of your entire compliance program.
2. Program Design: We develop your AML/CTF program, including all required policies, procedures and controls. These are written clearly to help your team understand and apply them in practice.
3. CDD and KYC Framework: We design a customer due diligence process suited to your business, covering initial CDD, ongoing monitoring, enhanced CDD for higher-risk customers and PEP and sanctions screening.
4. Registers and Reporting: We set up your SMR, IFTI/TTR, vetting and training registers, so your record-keeping obligations are covered from day one.
5. Staff Training: We provide AML/CTF training tailored to your team’s roles and the specific ML/TF risks they face in your business.
6. Compliance Officer Support: If you need ongoing support for your AML/CTF Compliance Officer, our AMLCO Support Services keep you covered between reviews and when complex issues arise.

Our AML/CTF Program Packages

• Consult: Bespoke AML/CTF program, including risk assessment.
• Consult +: Bespoke AML/CTF program, including risk assessment and a video guide for implementation into your business.
• Consult Premium: Bespoke AML/CTF program, including risk assessment, SAR, training, vetting, reporting registers and a video guide or personal walkthrough for implementation.

All pricing is POA based on your business size, sector and complexity.

Why Choose One AML?

We have helped over 1,000 reporting entities across Australia and New Zealand meet their AML/CTF obligations. Our team includes specialists with deep regulatory knowledge across financial services, real estate, law, accounting, crypto and more.

We are independent. We are not affiliated with AUSTRAC or any regulator. Our job is to make compliance straightforward and sustainable for your business.

• 70+ verified Google reviews
• Experience across all regulated sectors
• Programs built for businesses from sole traders to enterprise scale
• Practical, plain-language documentation your team will actually use
• Ongoing advisory and AMLCO support available after program delivery