---
title: "AML/CTF — the practice as a reporting entity"
url: "https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity"
type: "obligation"
site: "AI Law Framework"
id: "A52OB"
task_count: 6
last_reviewed: "2026-09-28"
---

# AML/CTF — the practice as a reporting entity

> Decide capture before anything else — Nothing on this page applies until the practice provides a designated service in Table 6 of subsection 6(5B) of the AML/CTF Act with a geographical link to Australia.…

Canonical page: https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity  
Last reviewed: 2026-09-28

Site index for agents: https://ailawframework.com/llms.txt

Decide capture before anything else — Nothing on this page applies until the practice provides a designated service in Table 6 of subsection 6(5B) of the AML/CTF Act with a geographical link to Australia. Map the work first and record the date the mapping was approved. The program, the due diligence and the reporting all follow from that map and from the enrolment date.

This is what the practice owes, not what the client owes — Every deliverable here goes to AUSTRAC, to the practice's governing body or onto the practice's compliance file. Advising a client about its own AML obligations is practice-area work and belongs elsewhere in the catalogue.

Privilege and tipping off stay with the lawyer — Section 242 preserves the law of legal professional privilege, and section 41(2)(aa) allows extra time to report where some of the information is privileged. Decide the position on each item, record the basis, and let no tool write a line of the report or of what is said to the client.

Use AI where the work is a register — The captured-services map and the customer due diligence record are prescribed internal records built from documents the lawyer has already collected, and that is where a tool earns its place. The risk assessment describes this practice and must be directed by the lawyer; a sector template rated as though it were the practice's own risk is a compliance failure, not a shortcut.

## Key facts

- Tasks: 6
- Green: 1, Yellow: 3, Red: 2
- Levels: Green is AI drafts and the lawyer checks; Yellow is lawyer and AI draft together; Red is the lawyer writes and AI may only check, clarify or collect data.

## Basis

Planning guidance checked on 27 September 2026. Confirm the current instrument before reliance.

## Tasks (6)

| Task | Level | How AI is used | What the lawyer must review |
| --- | --- | --- | --- |
| Map the practice's work against the designated services | Yellow | From the practice's matter-type list and the files opened over the last twelve months, build a row for each matter type against each item of Table 6 in… | The principal reads every row against what the practice does on those files rather than against the matter-type label: an estate administration that sells… |
| Build the practice's risk assessment and AML/CTF policies | Yellow | Working from the captured-services map, the client and country profile of the practice's own files and the channels it delivers through, build the risk… | The assessment must describe this practice, not the sector: check that every client type, service, channel and country in it is one the practice actually has,… |
| Assemble the customer due diligence record before the service starts | Green | From the identity documents, the company or trust extracts and the engagement papers the lawyer has collected, populate the practice's CDD record: extract… | Read each extracted detail against the document it came from, not against the summary: a transposed date of birth or a stale company extract is a verification… |
| Decide and record enhanced due diligence on a higher-risk client | Yellow | Assemble the indicators the file actually shows — the entity structure, the countries involved, the payment route, the pattern against the practice's risk… | The lawyer decides whether the file is higher risk and which measures apply; a rating the tool produced is an input, never the decision.… |
| Prepare the suspicious matter report | Red | Index the file into a dated chronology of instructions, transactions, communications and documents that the practitioner reads while writing the report, list… | The suspicion is the practitioner's, formed on reasonable grounds, and the grounds must be in the practitioner's own words.… |
| Decide what may be said to the client once a suspicion is reported | Red | Assemble the material the practitioner reads before deciding — the categories of information in section 123(2), the exceptions in section 123 with the ones… | The practitioner writes the note. Confirm that any exception relied on is actually in operation — AUSTRAC's guidance records that section 123(5), the… |

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*