AML/CTF
Anti-Money Laundering & Counter-Terrorism Financing.

AUSTRAC's regime for customer due diligence, ongoing monitoring, suspicious matter reporting, and international transfer reporting. Tranche 2 reforms extend the regime to lawyers, accountants, and other gatekeepers from 2026.

The stakes
AUSTRAC penalties are among the largest regulatory fines in Australia — Westpac and CommBank have each faced settlements exceeding $700M. AUSTRAC enforces with an audit-trail-and-intent-to-prosecute posture: half-baked controls and missing evidence are not negotiable defects.

What AML/CTF requires.
How BackPro handles each obligation.

Part B

AML/CTF program & risk assessment

The requirement

Maintain an AML/CTF program tailored to the firm's specific ML/TF risks. The program must be reviewed and updated regularly, and approved at senior management or board level.

Pt II Div 4

Customer due diligence (CDD)

The requirement

Verify customer identity and the beneficial ownership of legal entities before establishing a business relationship. KYC documentation must be retained for seven years.

Pt II Div 4 + Ch 4 Rules

Enhanced CDD (ECDD)

The requirement

Apply enhanced verification to customers presenting higher ML/TF risk: politically exposed persons, complex ownership structures, jurisdictions of concern, high-value cash relationships.

Pt II Div 6

Ongoing customer due diligence

The requirement

Monitor customer activity for inconsistency with the customer profile. Update customer information as circumstances change. Re-assess customer risk on a cadence proportionate to risk.

s 41

Suspicious matter reporting (SMR)

The requirement

Report suspicious matters to AUSTRAC within 24 hours (terrorism financing) or 3 business days (general). Maintain the supporting analysis that explains the basis of the suspicion.

s 45

International funds transfer instructions (IFTI)

The requirement

Report international funds transfers to AUSTRAC on the prescribed cadence. Maintain threshold transaction reports for cash transactions of $10,000 or more.

What BackPro produces for AML/CTF.

The artifacts your auditor expects. Hashed, signed, timestamped, exportable. Generated continuously while you work, not assembled in the week before the audit.

Artifact
AML/CTF program (board-approved)

Living program document with control mapping, version history, and approval trail.

Artifact
Customer KYC files

CDD evidence per customer, with beneficial ownership documentation and seven-year retention.

Artifact
ECDD records (high-risk customers)

PEP/sanctions screening, source-of-funds narrative, and senior-officer approval per high-risk relationship.

Artifact
Transaction monitoring report

Pattern-based alerts with reviewer disposition and rationale.

Artifact
Suspicious matter report (SMR)

AUSTRAC-formatted SMR with underlying analysis preserved.

Artifact
IFTI reporting pack

Periodic IFTI submissions plus threshold transaction reports in AUSTRAC's prescribed schema.

Tranche 2 · By profession

How AML/CTF lands in your profession.

Tranche 2 captures six new categories of reporting entity from 1 July 2026. We have written a dedicated read for each — what changes, the real-world scenarios, the obligations in operational order, and how to get ready.

See AML/CTF mapped to your own controls.

Forty‑five minutes with our team. We take your existing control register, map it against AML/CTF obligations, and show you which gaps BackPro closes automatically. The mapping is yours to keep whether you proceed with us or not.