AML/CTF Program (AUSTRAC)

Overview

Create and validate Part A and Part B of the Anti-Money Laundering and Counter-Terrorism Financing Program for Australian reporting entities (finance, casinos, bullion dealers). Part A covers risk management, ongoing and enhanced CDD, transaction monitoring, SMR, and record-keeping; Part B documents customer identification (KYC) and Safe Harbour verification procedures for individual customers. Use austrac_risk_profiler in the same project to assess customer risk (PEP, SMR logic).

Validation tool

kyc_procedure_audit — Checks that the AML/CTF Program (Part B or customer identification section) includes Safe Harbour verification procedures for individual customers: (1) verification of identity (not just collection), (2) use of reliable and independent documentation or electronic data, (3) at least one primary document type (e.g. passport, driver licence, birth certificate), and (4) scope to individual customers. Run it on the program or Part B after drafting or updating to catch missing elements before finalising.

Example

You: We’re updating our AML/CTF Program. I’ve revised Part B in compliance/aml-ctf-program.md. Can you check that Safe Harbour verification for individual customers is covered?

Agent: I’ll run the KYC procedure audit. (Runs kyc_procedure_audit.) The audit shows verification and reliable and independent documentation are stated, and primary document types are listed. Consider explicitly stating that these procedures apply to individual customers. I can suggest wording from the Safe Harbour reference if you want.

Excerpt of a generated document

The following is an excerpt from a Part B section the agent might produce (the validator would confirm Safe Harbour elements are present):

## Customer identification — Individual customers (Safe Harbour)

For individual customers where the business relationship presents medium or lower ML/TF risk, we verify identity using **reliable and independent** documentation and/or electronic data.

**Document-based verification:** We require at least one primary document (e.g. Australian or foreign passport, Australian driver licence, national identity card, or birth certificate) and, where applicable, one secondary document (e.g. utility bill or rates notice issued within the last three months) showing current name and address.

**Electronic verification:** Where permitted by the AML/CTF Rules, we may verify identity using electronic data from reliable and independent sources. [Specify systems and when used.]

Getting Started

Add your AML/CTF Program draft (or Part A / Part B sections) to the project workspace, then activate the AML/CTF Program (AUSTRAC) skill. Use austrac_risk_profiler to support risk-based application of Safe Harbour (medium or lower risk) vs enhanced CDD.