AML Risk Assessments and Policies

Implementing strong AML Risk Assessments and Policies is essential for businesses to stay compliant with Australia’s anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. Effective risk assessments and well-designed policies help organizations identify vulnerabilities, monitor transactions, and prevent financial crime.Australia’s Tranche 2 AML Reforms mark a significant expansion of the country’s anti-money laundering (AML) and counter-terrorism financing (CTF) laws. These reforms bring a broader range of businesses under AUSTRAC regulation, ensuring that higher-risk sectors implement strict compliance measures to prevent financial crime.

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Why AML Risk Assessments and Policies Matter Now?

Many Australian businesses are realizing for the first time that they need proper AML documentation. AML Risk Assessments and Policies are no longer optional they are a regulatory requirement under AUSTRAC’s AML/CTF framework.Tranche 2 AML Reforms are a set of new Australian laws that extend anti-money laundering (AML) and counter-terrorism financing (CTF) rules to more businesses. They are designed to make it harder for criminals to use professional services to hide or move illegal money.

Without them, your business risks:
  • Regulatory scrutiny and fines
  • Compliance gaps that can damage reputation
  • Inefficient processes that make managing risk harderThe goal is to stop money laundering and terrorism financing and ensure all businesses follow consistent rules.

Getting AML Risk Assessments and Policies right from the start makes compliance simpler, reduces fear and uncertainty, and protects your firm long-term.

What AML Risk Assessments and Policies are required to have

Under Australia’s AML/CTF regulations, businesses are required to have AML Risk Assessments and Policies that are tailored to their operations and risk profile. Here’s what that includes:

  • AML Risk Assessment
    A documented assessment that:
    - Identifies and evaluates money laundering and terrorism financing risks relevant to your business
    - Covers your services, clients, transaction types, and geographic exposure
    - Considers the use of trust accounts, third-party funds, and delivery channels
    - Reflects your actual operations, not generic templates
  • AML Policies and Procedures
    A written program that explains how your firm manages the risks identified in your risk assessment. This includes:
    - Customer due diligence (KYC) and enhanced due diligence for higher-risk clients
    - Source of funds and source of wealth checks
    - Ongoing monitoring of client relationships and transactions- Reporting suspicious matters (SMRs) and threshold transactions (TTRs)
    - Record keeping and document retention
    - Staff training and compliance oversight
  • Governance and Oversight
    Policies must also include:- Clear responsibilities for staff and management
    - Appropriate training programs
    - Regular reviews and updates of risk assessments and procedures
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Key takeaway: Your AML documentation must reflect how your business actually operates, the types of clients you serve, and your specific risk exposure. Generic templates or copy-paste programs are not sufficient.

 AML risk assessments

An AML Risk Assessment is the foundation of your compliance framework. It identifies how and where your business may be exposed to money laundering or terrorism financing risks and helps you decide what controls are needed to manage those risks.

What an AML Risk Assessment Covers:

  • Services Provided: The types of services your business offers that may be high risk.
  • Client Base: Who your clients are, how they are onboarded, and their risk profile.
  • Transaction Types: Payment methods, transaction volume, and complexity.
  • Geographic Exposure: Risks associated with clients or transactions in high-risk jurisdictions.
  • Trust Accounts or Third-Party Funds: How you manage client money.
  • Delivery Channels & Outsourcing: Risks from remote or third-party services.
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At One AML, we create tailored AML Risk Assessments that:

  • Reflect how your business actually operates
  • Are defensible and aligned with AUSTRAC guidance
  • Focus on practical risk management, not unnecessary complexity

Key Areas Covered in an AML Risk Assessment

A thorough AML Risk Assessment looks at all aspects of your business that could be exposed to financial crime. This typically includes:

  1. The Types of Services You Provide
    Different services carry different levels of risk. For example, setting up trusts, managing client funds, or handling high-value transactions may attract higher scrutiny.
  2. Your Client Base and How Clients Are Onboarded
    Understanding who your clients are and how you verify their identity (KYC) helps identify higher-risk relationships.
  3. Transaction Types and Payment Methods
    Certain transactions or payment methods (cash, international transfers, or complex structures) can increase AML risk.
  4. Geographic Exposure
    Doing business with clients or jurisdictions considered high-risk for money laundering or terrorism financing requires additional scrutiny.
  5. Use of Trust Accounts or Third-Party Funds
    Holding client money in trust or handling funds on behalf of others carries unique responsibilities and risks that must be monitored.
  6. Delivery Channels and Outsourcing Arrangements
    Remote services, online platforms, or third-party providers may introduce additional compliance risks that need to be controlled.

AML Policies and Procedures: Turning Risk into Practical Controls

Your AML policy explains how your firm manages the risks identified in your risk assessment. It turns risk into clear, actionable procedures that your team can follow every day.

Key Components of an AML Policy:

  1. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD): Verify client identities and assess higher-risk relationships.
  2. Source of Funds and Source of Wealth Checks: Understand where clients’ money comes from and ensure it is legitimate.
  3. Ongoing Monitoring: Keep an eye on client relationships and transactions to spot unusual activity.
  4. Reporting Obligations: Submit Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) when required.
  5. Record Keeping: Maintain accurate, accessible documentation of compliance activities.
  6. Staff Training and Oversight: Ensure employees understand AML requirements and management monitors adherence to procedures.

At One AML, we create practical policies that your team can actually use, not documents that sit on a shelf. Our approach ensures your policies support day-to-day operations while fully meeting regulatory expectations.

Proportionate and Scalable: Compliance That Fits Your Business

AUSTRAC expects AML compliance frameworks to be risk-based and proportionate. Small and medium-sized firms aren’t expected to have the same complexity as large financial institutions.
At One AML, we design AML risk assessments and policies that are:

  1. Appropriate: Tailored to your firm’s size, services, and risk profile
  2. Scalable: Easy to expand as your business grows
  3. Flexible: Simple to update as AUSTRAC guidance or your operations change
  4. Defensible: Documented in a way that stands up to regulatory review

Our focus is on practical, usable compliance—not overly complex systems or one-size-fits-all templates. This ensures your firm is protected, compliant, and ready for the long term without unnecessary bureaucracy.

How One AML Supports Tranche 2 Readiness

Preparing for AML compliance doesn’t have to be overwhelming. One AML guides your business through the process efficiently, ensuring your AML risk assessments and policies are done right the first time.
Our support typically includes:

  1. Tailored AML Risk Assessments: We document your specific risks based on how your business actually operates.
  2. AML Policies and Procedures: Practical, easy-to-use policies that your team can follow daily.
  3. Integration with Your Processes: Aligning AML compliance with existing onboarding, governance, and operational procedures.
  4. Practical Guidance on Implementation: Step-by-step advice to make compliance simple, manageable, and sustainable.

With One AML, you gain:

  1. Confidence that your business meets AUSTRAC expectations
  2. A proportionate, scalable compliance framework
  3. Peace of mind that your AML documentation is defensible and effective

We focus on practical solutions, not over-engineered templates, so your business can remain compliant without unnecessary complexity.