---
title: "Build the firm's client-acceptance and cash-reporting procedure"
url: "https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/build-the-practice-s-risk-assessment-and-aml-ctf-policies/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A52OB-X20260927-2-US"
practice_area: "AML/CTF — the practice as a reporting entity"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build the firm's client-acceptance and cash-reporting procedure

> Turn the lawyer's instructions into a procedure covering the Rule 1.16 inquiry and the steps for a Form 8300. Do not write a suspicious-activity program as if the firm were a casino or a bank.

Canonical page: https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/build-the-practice-s-risk-assessment-and-aml-ctf-policies/united-states  
Last reviewed: 2026-10-22

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

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [AML/CTF — the practice as a reporting entity](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Turn the lawyer's instructions into a procedure covering the Rule 1.16 inquiry and the steps for a Form 8300. Do not write a suspicious-activity program as if the firm were a casino or a bank. |
| What the lawyer must review | Model Rule 1.16(a) requires the lawyer to inquire into and assess the facts and circumstances of each representation, and to decline or withdraw where the client seeks to use the lawyer's services to commit or further a crime or fraud. A required Form 8300 is filed within 15 days, electronically with FinCEN or on paper with the IRS. Check the admitting state's version of Rule 1.16. Do not describe this procedure as an AUSTRAC AML/CTF program. |
| Written for | United States |
| Applies to | [Build the practice's risk assessment and AML/CTF policies](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/build-the-practice-s-risk-assessment-and-aml-ctf-policies.md) |

## Checking plan

- What the AI does: Turn the lawyer's instructions into a procedure covering the Rule 1.16 inquiry and the steps for a Form 8300. Do not write a suspicious-activity program as if the firm were a casino or a bank.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Section 6050I(f) prohibits causing a trade or business to fail to file a required return, or to file one with a material omission.
- The state's adoption of Rule 1.16 may differ from the ABA text. Open that version.

## Sources

- [ABA Model Rule 1.16, Declining or Terminating Representation](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_16_declining_or_terminating_representation/) (checked 2026-10-22)
- [IRS: Form 8300 and reporting cash payments of over $10,000](https://www.irs.gov/businesses/small-businesses-self-employed/form-8300-and-reporting-cash-payments-of-over-10000) (checked 2026-10-22)
- [26 U.S.C. § 6050I (returns relating to cash received in a trade or business)](https://www.law.cornell.edu/uscode/text/26/6050I) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [AUSTRAC enrolment form for a reporting entity](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/form-austrac-enrol-business.md) | Form | Yellow | Link to AUSTRAC's enrol-a-business form in AUSTRAC Online. A business that provides a designated service with a geographical link to Australia must enrol. |
| [Independent evaluation of the practice AML/CTF program](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/independent-evaluation-preparation.md) | Checklist | Yellow | A checklist for an independent evaluation of a legal practice AML/CTF program: who may evaluate it, what they must be given, who receives the written report, and how adverse findings are answered. |
| [ML/TF risk assessment record for a legal practice](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/mltf-risk-assessment-record.md) | Form | Red | Record of the practice's own ML/TF risk assessment under s 26C: the services, customers, channels and countries it actually has, the ratings the compliance officer gives, and the senior manager's… |
| [First independent evaluation deadline for the practice](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/first-independent-evaluation-deadline.md) | Checklist | Yellow | A worksheet for the first independent evaluation date on AUSTRAC's transitional-rules page: the four AUSTRAC account-number patterns, and the later-of rule for an existing reporting entity. |
| [Legal profession AML/CTF program review triggers](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/program-review-trigger-register.md) | Checklist | Yellow | A register of the events AUSTRAC's legal-profession maintain-and-review page says should trigger a review of the practice program, and the process or form that page names for each event. |
| [Deadline to notify AUSTRAC of the AML/CTF compliance officer](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/compliance-officer-notification-deadline.md) | Checklist | Yellow | A diary for the date by which the practice notifies AUSTRAC of its AML/CTF compliance officer, using the two limbs on the transitional-rules page. |
| [AML/CTF record retention schedule for the practice](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/aml-record-retention-schedule.md) | Policy | Yellow | Schedule of how long the practice keeps AML/CTF program records, customer due diligence records and transaction records, using the periods AUSTRAC states for ss 116, 111 and 107, and who may destroy… |

Signed-in accounts can read the full text of each one.

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