AML/CTF checklist
AML/CTF program readiness checklist
If you provide a designated service under s 6 of the AML/CTF Act, you must adopt and maintain a Part A and Part B program. Tranche 2 reforms — commencing 1 July 2026 for many lawyers, accountants and real estate professionals — will bring ~100,000 new reporting entities into scope. This checklist scores your program readiness across 10 control areas.
Last verified: 5 June 2026
Question 1 of 1010%
This checklist is a structured prompt — not legal advice. It cites the relevant Act and section against each item so you can verify the source. Engage a qualified adviser before relying on the output for board, regulator or transaction purposes.
Frequently asked questions
- When does Tranche 2 commence?
- The AML/CTF Amendment Act 2024 commences in stages — most program reforms on 31 March 2026, with the new Tranche 2 designated services (lawyers, accountants, real estate, trust and company service providers, high-value dealers) commencing on 1 July 2026.
- What is the difference between Part A and Part B?
- Part A is the risk-based program: ML/TF risk assessment plus systems and controls. Part B is the customer due diligence program: KYC procedures for identifying and verifying customers. Both are required under s 84.
- Who must appoint an AMLCO?
- Every reporting entity (s 84(2)(c)). The AMLCO must be at management level, with sufficient authority and resources, and have access to relevant information.