Program template
AML/CTF program template for solicitors, conveyancers, settlement agents
A sample AML/CTF program for a small Australian firm: purpose, designated services, risk assessment, compliance officer, customer due diligence, reporting, record keeping, training and review. See the full document and print it.
The sample below is for a fictional four-person practice. It has the ten sections AUSTRAC looks for. Names and numbers are made up.
See the sample program
Enter your work email and the full document opens on this page. Print it or save it as PDF.
Questions people ask
- What must an AML/CTF program contain?
- Two parts: a money laundering and terrorism financing risk assessment of your firm (clients, services, delivery channels, jurisdictions) and the policies and procedures you use to manage that risk: customer due diligence, ongoing monitoring, reporting, record keeping, staff training and independent review. It must be approved by senior management and reviewed regularly.
- Can I just use this template as my program?
- Use it as a starting point. The sample is built for a typical small practice; your program must reflect your own services, clients and risks. Adopt it only after reading it and changing what does not fit. The software generates one from your own answers in about ten minutes.
- How often must the program be reviewed?
- Whenever your services, client base or the law changes, and in any case regularly; a yearly review is common practice and is what this template sets. The Act also requires an independent evaluation of the program at least once every three years; for newly regulated firms the Transitional Rules 2026 set the first deadline between 30 June 2029 and 31 December 2030 by AUSTRAC account number.
- Should I use AUSTRAC's free program starter kit instead?
- If your practice fits the profile AUSTRAC wrote the kit for (up to fifteen people, mostly individual Australian clients, no regular high-risk work), the kit is a sound and official starting point and you should read it. This template and the software cover the same ground in fewer pages and add what a document set cannot: versioning, client records with review dates, reporting deadlines, training records and an audit trail. Many firms use both: the kit to check completeness, the software to run the program.
Set up your program in the first ten minutes.
Fourteen days free. No card details until you decide to keep it.