Policy · AML/CTF — the practice as a reporting entity

AI and automated tools in the AML/CTF program: control standard

Control standard to insert into a legal practice's AML/CTF program covering e-verification, screening, document checks and generative AI: approval and validation, deepfake and synthetic document risks, human review, records, change control and tipping-off safeguards.

Kind
Policy. A policy or procedure for a firm or client.
Where it applies
Australia
AI use
Yellow AI can help in set ways. A lawyer checks specific points before use.
Law stated as at
17 October 2026
Status
Maintained. Checked against the cited sources on 17 October 2026.
Version
1
Source
Written for this library

When to use it

Adopt as part of the AML/CTF policies (s 26F) of any practice that uses electronic verification, screening, monitoring or generative AI tools in its AML/CTF work, or offers remote or AI-assisted onboarding. Review whenever a tool, vendor or model changes.

How AI may be used

AI may support CDD record-building, document indexing and alert triage under these controls, but the compliance officer approves tools and thresholds, and people make every risk, match, escalation and reporting decision.

AI may

  • Populate CDD records from documents already collected and list fields without a source.
  • Index a file into a dated chronology for the practitioner preparing an SMR, inside an approved secure environment.
  • Summarise screening alerts for human review, showing the matching data.

AI must not

  • Must not write any part of a suspicious matter report or decide whether to report.
  • Must not receive suspicion or SMR information in any external or general-purpose AI tool.
  • Must not draft communications to a client after a suspicion has formed.

The lawyer checks

  • Each tool was validated before use and after each material change, with results recorded.
  • Every alert and potential match was reviewed by a person with reasons recorded.
  • Access to AML/CTF information in tools is limited to those with a need to know.

Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.

Authorities

Official form

Open the official form. Always use the current version from the issuer.

Read the full text

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