AML/CTF Program (Item 54 only) - AFSL

Financial advisers with their own AFSL must have an AML/CTF Program. If you only provide Item 54 Designated Services you can use this use this modified Program bundle.

This reduced suite of documents includes:

• our AML/CTF Policies (AML/CTF Program)
• our ML/TF Risk Register (which includes our ML/TF Risk Assessment)
• other supporting tools, registers and checklists

Our Program is broken into the following six chapters:

1. Introduction
2. ML/TF Riks Assessment
3. Personnel and Governance
4. Customer Due Diligence (CDD)
5. AUSTRAC Enrolment and Reporting
6. Program Maintenance and Review

There are over 20 support tools, registers and checklists, including:

• ML/TF Risk Register
• KYC Tool

To support you in customising this bundle, we have also included a Guide to customising your AML/CTF Program & Tools.

Important: At the time of release there remains a number of guidelines still outstanding. This coupled with AUSTRAC releasing the AML/CTF Rules and its guidance later than expected, has resulted in a compressed timeframe to produce our updated AML/CTF Program template. We are releasing this version now, so our customers have sufficient time to review and prepare their updated AML/CTF Program in advance of the 2026 commencement dates.

An outstanding issue for item 54 providers includes how Reporting Groups will operate where the Australian Financial Services (AFS) licensee authorises Corporate Authorised Representatives (CARs) externally to its own entity.

Endnotes and some source references have not been finalised in this version. We also anticipate multiple refinements over the next few months as AUSTRAC publishes additional guidance and as we receive user feedback.

To support you as you transition to the new regime, if you purchase this manual between now and 30 June 2026, you will be entitled to receive any updated versions of the manual and supporting tools until 30 June 2026 at no additional charge.