AML/CTF Report
As an Australian reporting entity, you must submit your anti-money laundering and counter-terrorism financing (AML/CTF) compliance report (Compliance Report) to AUSTRAC, for the period from 1 January 2024 to 31 December 2024. Compliance Reports are important tools for AUSTRAC as they help AUSTRAC to target their resources to areas of high risk. This is because Compliance Reports help AUSTRAC understand your business and your sector, and the threats that you, and other businesses in your sector, face.
It is very important to ensure that your Compliance Report is completed accurately and in a timely manner as there can be penalties for failing to submit your Compliance Report.
Here are some practical steps to ensure your Compliance Report is timely and accurate.
What
Make sure that the information required for the Compliance Report is available to you before you start the process. AUSTRAC has published a list of preview questions, which you can find here. In general, you can expect to be asked to provide information about:
Products and services offered
Information on your staff (e.g., number of employees, changes to key personnel)
Methods you used to provide designated services (e.g., email, face-to-face, mobile application)
Any outsourcing services you use for your AML/CTF compliance
Information on your AML/CTF programme and risk assessment (e.g., internal reviews, independent reviews)
Information on your AML/CTF training
Number and types of customers, identification processes for customers, high-risk customers and enhanced customer due diligence
Transaction monitoring programme, including unusual or potentially suspicious activity monitoring and reporting
Feedback on AUSTRAC guidance and regulatory approach
When
You can submit your Compliance Report at any time from 1 January to 31 March 2025. Avoid waiting until the last minute to prepare your Compliance Report, because:
Information gathering may be time-consuming. Start reconciling the information as soon as possible.
You will need an AUSTRAC Online account to submit your Compliance Report. If you do not have one already, ensure to allow time to complete the registration.
Senior managers need to have oversight of the Compliance Report process, and the best practice is for them to approve the Compliance Report before this is finalised and submitted.
How
AUSTRAC provides a step-by-step process to complete the Compliance Report, which is as follows:
Log in to AUSTRAC Online
Go to ‘My Business’
Click the plus sign (+) next to ‘My Business’ to see more menu options
Select ‘Compliance Reports’
Select ‘Open Compliance Report’ for the applicable year
Complete the questions
Review and submit
Record-Keeping for Compliance Reports
The key to a successful Compliance Report is an effective record-keeping process throughout the year.
Record-keeping is the cornerstone of AML/CTF. Developing solid record-keeping procedures, with clear responsibilities and oversight, will help you to comply with your AML/CTF requirements. There is no prescribed form of record-keeping, and spreadsheets and file notes may be fine for many small reporting entities (get in touch if you need a spreadsheet template to manage your AML/CTF compliance). Bigger and more complex entities might need to rely on software.
What’s Next?
Get in touch if you need any help with your Compliance Report or your record-keeping.
