What Does It Contain?
A compliant AML/CTF Program consists of two parts:
Part A: Risk Management and Controls
Risk Assessment - Evaluating ML/TF risks based on customers, services, delivery channels, and geographic exposure
Board/Senior Management Oversight - Approval and ongoing program oversight
AML/CTF Compliance Officer (AMLCO) - Designated officer managing day-to-day compliance
Employee Due Diligence - Staff screening and management procedures
Transaction Monitoring - Systems detecting suspicious activities and unusual patterns
Reporting Procedures - Processes for submitting required reports to AUSTRAC
AUSTRAC Feedback - Procedures for addressing regulatory guidance
Training and Awareness - Regular employee training programs
Record Keeping - Maintaining records for seven years
Internal Controls - Robust governance structure with oversight mechanisms
Independent Audit - Regular independent program effectiveness reviews
Part B: Customer Identification and Verification
Customer Due Diligence (CDD) - Identifying and verifying customers and beneficial owners
Enhanced Due Diligence (EDD) - Additional measures for high-risk customers (PEPs, high-risk jurisdictions)
Beneficial Ownership - Identifying individuals controlling entities
Verification Methods - Acceptable documents and verification processes
Timing Requirements - When identification must occur
Ongoing Due Diligence - Periodic customer information reviews
Key Considerations
Your program must reflect your actual operations, not a generic template. Consider operational feasibility, technology integration, customer experience, resource allocation, sector-specific requirements (legal privilege, confidentiality), and proportionality to your size and risk profile.
How VerifiMe Supports Your AML/CTF Program
Part B: Customer Identification
Automated verification for individuals, companies, trusts, and associations
Beneficial ownership identification for complex structures
Real-time verification against government databases
Document verification and secure storage
Part A Support
Risk assessment scoring tools
Seven-year digital record keeping with audit trails
Ongoing monitoring for periodic reviews
PEP screening and sanctions list checking
What VerifiMe Doesn't Replace
You still need to develop: your specific risk assessment, governance structures, employee training programs, transaction monitoring procedures, internal reporting processes, and suspicious matter detection procedures.
Independent Review Requirements
Your unified AML/CTF program must be independently and regularly reviewed by someone who has not been involved in the development of the Business-Wide Risk Assessment (BWRA) or the related internal systems and controls of the unified program. (Excludes the AML/CTF Compliance Officer).
Getting Expert Support
We can refer you to experienced AML/CTF consultants who specialize in Tranche 2 compliance to help with risk assessments, program drafting, governance structures, training materials, and monitoring procedures.
Contact us to discuss how VerifiMe can streamline your compliance obligations and for referrals to qualified consultants.
Disclaimer: This document provides general information and is not legal advice. Consult legal advisors and AUSTRAC guidance when developing your compliance framework.
Visit: www.austrac.gov.au