AML/CTF Tranche 2 program Current

Building your firm's AML/CTF program

A step-by-step outline for firms newly regulated under Tranche 2.

Reporting entities need a documented AML/CTF program that sets out how the firm identifies and manages money-laundering and terrorism-financing risk. This guide walks through the practical steps. It is general information, not legal or compliance advice.

Action plan

1 Assess your money-laundering and terrorism-financing risk Understand the risk profile of your clients, services and delivery channels.

A risk assessment looks at your firm's clients, the designated services you provide, how you deliver them, and the jurisdictions involved, to understand where money-laundering and terrorism-financing risk is higher or lower. Vertical Flows can structure the intake and evidence capture a risk assessment relies on. It does not perform the risk assessment for you.

  • Consider your client types, services, delivery channels and jurisdictions
  • Identify where your firm's risk is higher and needs closer controls
  • Document the assessment and who approved it

Done when: A documented risk assessment is in place and approved

AUSTRAC: Tranche 2 obligations factsheet
2 Document policies, procedures and controls Set out how your firm applies AML/CTF controls in practice.

Your AML/CTF program should document the policies, procedures and controls your firm applies, covering customer due diligence, ongoing monitoring, record keeping and reporting. Vertical Flows supports the structured intake, evidence capture and review workflow a program relies on. It does not draft or certify the program itself.

  • Document your customer due diligence and ongoing monitoring procedures
  • Document your record-keeping and reporting procedures
  • Have the program approved at the appropriate level in your firm

Done when: A documented AML/CTF program covering policies, procedures and controls is approved

See how structured intake and review works
3 Assign an officer and set a review cycle Name who is accountable for the program and when it will next be reviewed.

Assign an AML/CTF compliance officer accountable for the program's day-to-day operation, and set a cycle for reviewing and updating the program as your firm's services or risk profile change.

  • Name your AML/CTF compliance officer
  • Set a review cycle for the program
  • Record each review and any changes made

Done when: An accountable officer is named and a program review cycle is documented

AUSTRAC: Tranche 2 obligations factsheet