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.
Official form
Open the official form. Always use the current version from the issuer.
Read the full text
The full text is for signed-in accounts. It is free. When you sign in you can:
- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
More in AML/CTF — the practice as a reporting entity
- AML/CTF program for small legal practices: AUSTRAC legal profession starter kit adoption guide
- Designated services capture map and enrolment decision record (AML/CTF Act s 6(5B), table 6)
- Initial customer due diligence checklist for law practice designated services
- Suspicious matter escalation, reporting and legal professional privilege procedure
- Client letter: why we need to verify your identity (AML/CTF obligations)
All precedents for AML/CTF — the practice as a reporting entity · Tasks and AI use in this area