Your Obligations & Your Firm's AML/CTF Programme

Your Obligations as an Individual Practitioner

AML/CTF obligations are not only institutional — they attach to individual practitioners. As a staff member of a reporting entity, you are personally responsible for:

• Completing this mandatory training before handling designated services and refresher training at least annually thereafter
• Conducting and recording CDD for all new client engagements involving designated services, in accordance with the firm's programme
• Reporting suspicions promptly to your AML/CTF Compliance Officer — not holding them until the next convenient moment
• Never disclosing to a client, colleague, or third party that a suspicious matter report has been or may be made
• Maintaining records of CDD and transaction monitoring in accordance with the 7-year retention requirement
• Keeping your knowledge of the firm's AML/CTF programme current — including when it is updated following regulatory changes

Your Firm's AML/CTF Programme — What It Covers

Your firm is required to maintain a written, risk-based AML/CTF programme. This is the central document governing how your firm complies with its AUSTRAC obligations. You are expected to know it exists, know where to find it, and follow its procedures.

A compliant AML/CTF programme must include ten sections covering:

• Part A — ML/TF risk assessment: the firm's overall assessment of its exposure to money laundering and terrorism financing risk, based on its client base, services, delivery channels, and geographic exposure
• Part B — Customer identification and verification: the specific procedures for identifying and verifying each client type
• Part C — Enhanced CDD: procedures for PEPs, high-risk jurisdictions, and other high-risk client categories
• Part D — Ongoing CDD: how the firm monitors existing client relationships and updates client information
• Part E — Employee due diligence: how the firm screens and monitors staff who handle AML/CTF matters
• Part F — AML/CTF risk awareness training: this training programme is Part F
• Part G — Compliance management: how the firm identifies, manages, and reports AML/CTF compliance issues
• Part H — Suspicious matter reporting: the internal escalation and external reporting procedures
• Part I — Record keeping: what records are kept, for how long, and in what format
• Part J — Programme review: how and when the firm reviews and updates the programme

Your AML/CTF Compliance Officer

Your firm must designate an AML/CTF Compliance Officer — a senior individual with responsibility for overseeing the firm's compliance with its AML/CTF programme. The Compliance Officer is your first point of contact for any AML/CTF concern.

Go to your Compliance Officer when:

• You identify red flags or form a suspicion about a client or matter
• A client refuses to provide CDD information or appears to be providing false information
• You are unsure whether a service is a designated service under the AML/CTF Act
• You receive a request that seems unusual, unexplained, or inconsistent with the client's known profile
• You receive any inquiry, notice, or request from AUSTRAC or any law enforcement body
• A client or third party asks you about the firm's AUSTRAC reporting obligations

Record Keeping and Ongoing Compliance

The AML/CTF Act requires reporting entities to retain certain records for a minimum of 7 years. Records you must keep include:

• All CDD information collected for each client — identification documents, verification records, and risk assessments
• Records of all transactions involving designated services, including the nature and value of the transaction and the parties involved
• Copies of all suspicious matter reports submitted to AUSTRAC and the supporting records that led to the report
• Records of all AML/CTF training completed by staff, including dates, content, and assessment results — your completion of this training is recorded in Proximo Comply
• Records of all programme reviews and updates

Ongoing compliance is not a set-and-forget exercise. AUSTRAC issues updated guidance, enforcement actions, and typologies regularly. Your firm's AML/CTF programme must be reviewed and updated at least annually, and you are expected to complete refresher training when significant changes occur. Proximo Comply will notify you when refresher training is due.