AML/CTF checklist
AML/CTF program readiness checklist
If you provide a designated service under s 6 of the AML/CTF Act, you must have and comply with an AML/CTF program: an ML/TF risk assessment plus AML/CTF policies (the reformed structure that replaced the former Part A / Part B model from 31 March 2026). Tranche 2 reforms commenced on 1 July 2026 and brought tens of thousands of lawyers, accountants, real estate professionals and other businesses into scope. This checklist scores your program readiness across 10 control areas.
Last verified: 3 October 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 did Tranche 2 commence?
- The AML/CTF Amendment Act 2024 commenced in stages — the program reforms for existing reporting entities on 31 March 2026, and the new Tranche 2 designated services (lawyers, accountants, real estate, trust and company service providers, high-value dealers) on 1 July 2026. Both are in force now.
- Do Part A and Part B still apply?
- No. Part A (risk assessment plus systems and controls) and Part B (customer identification procedures) were the former structure. Under the reformed AML/CTF Act, the program is an ML/TF risk assessment plus AML/CTF policies (including CDD), with governance, a designated compliance officer and independent evaluation at least every 3 years.
- Who must appoint an AMLCO?
- Every reporting entity. The AMLCO must be at management level, fit and proper, with sufficient authority and resources, and have access to relevant information. AUSTRAC must be notified within 14 days of designation.