Manual
AML/CTF Program (Item 54 only) - AFSL
Last updated: 12 June 2026
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, specifically tailored for Item 54 providers
- 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:
- Introduction
- ML/TF Riks Assessment
- Personnel and Governance
- Customer Due Diligence (CDD)
- AUSTRAC Enrolment and Reporting
- Program Maintenance and Review
Included documents
| Document | Version | Type | Date |
|---|---|---|---|
| AML/CTF Policies (Item 54 only) | 5.0 | Program | 12 June 2026 |
| AML-CTF Policies - Marked-up version between V4.1 and V5 (Item 54 only) - AFSL | 1.0 | Policy | 12 June 2026 |
| Tool 1A. AML/CTF Glossary | 2.0 | Guide | 10 June 2026 |
| Tool 2A. Business Specific Data | 2.0 | Tool | 10 June 2026 |
| Tool 2B. ML/TF Risk Register and KYC Tool (Item 54 only) | 3.0 | Tool | 10 June 2026 |
| Tool 2C. Assessment of Proliferation Financing Risks Faced by our Business Template | 3.0 | Tool | 10 June 2026 |
| Tool 3A. Personnel Due Diligence and Training Register | 1.1 | Register | 10 June 2026 |
| Tool 3B. AML/CTF Standing Meeting Agenda Template | 1.1 | Tool | 10 June 2026 |
| Tool 3C. AML/CTF Compliance Officer Appointment and Ongoing Assessment Checklist | 1.1 | Tool | 10 June 2026 |
| Tool 3D. AML/CTF Compliance Officer Obligations and Procedures | 1.0 | Tool | 11 Jan. 2026 |
| Tool 3E. AML/CTF Compliance Officer Report Template | 1.1 | Tool | 10 June 2026 |
| Tool 3F. AML/CTF Personnel Due Diligence Declaration Template | 1.1 | Tool | 10 June 2026 |
| Tool 3G. External Service Provider Appointment Assessment Template | 1.1 | Tool | 10 June 2026 |
| Tool 3H. External Service Provider Ongoing Assessment Template | 1.1 | Register | 10 June 2026 |
| Tool 3I. Reporting Group Member Procedure | 1.1 | Tool | 10 June 2026 |
| Tool 3J. Reporting Group Member Register | 1.1 | Tool | 10 June 2026 |
| Tool 3K. Reporting Group Member Information Sharing Request Template | 1.1 | Tool | 10 June 2026 |
| Tool 4A. High-Risk Customer and ECDD Register | 1.1 | Tool | 20 March 2026 |
| Tool 4B. Identification of Individuals Without Standard Identification Documents Form | 1.2 | Register | 10 June 2026 |
| Tool 4C. Third Party CDD Arrangement Appointment and Ongoing Monitoring Procedure | 1.3 | Tool | 10 June 2026 |
| Tool 4D. Third Party CDD Arrangement - CDD Risk Assessment | 1.1 | Tool | 20 March 2026 |
| Tool 4E. Third Party CDD Arrangement - CDD Risk Assessment (Decommissioned) | 1.0 | Tool | 11 Jan. 2026 |
| Tool 5A. AUSTRAC Enrolment Form | 1.1 | Tool | 10 June 2026 |
| Tool 5B. Suspicious Activity Report | 1.1 | Register | 10 June 2026 |
| Tool 5C. Assessment of Suspicious Activity Form | 1.1 | Tool | 10 June 2026 |
| Tool 5D. Suspicious Matter Report Content Requirements Guide | 1.1 | Guide | 10 June 2026 |
| Tool 5E. Suspicious Activity Register | 1.1 | Tool | 10 June 2026 |
| Tool 5F. AUSTRAC Registration Form | 1.1 | Tool | 10 June 2026 |
| Tool 6A. AUSTRAC Guidance Register | 2.0 | Register | 10 June 2026 |
| Tool 6B. AML/CTF Program Review and Update Register | 1.0 | Register | 11 Jan. 2026 |
| Tool 6C. AML/CTF Document Destruction Schedule | 1.0 | Tool | 11 Jan. 2026 |
| Tool 6D. Assessment and Appointment of Independent Evaluator Checklist | 1.1 | Tool | 10 June 2026 |
| Tool 6E. Review and Response to Independent Evaluation Report | 1.1 | Tool | 10 June 2026 |
| AML/CTF Implementation Plan Template (Tranche 1 Reporting Entities Only) - All | 1.1 | Tool | 20 March 2026 |
| Guide to customising your AML/CTF Program and Tools (Item 54 only) | 1.1 | Guide | 20 March 2026 |
| AML/CTF Obligations Register - ACL, AFSL, All, Wholesale | 1.1 | Guide | 3 July 2026 |