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

AML/CTF record retention schedule for the practice

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 them.

Kind
Policy. A policy or procedure for a firm or client.
Where it applies
Australia
AI use
Yellow You and the tool draft together, with you directing. You check every statement you rely on.
Law stated as at
22 October 2026
Status
Maintained. Checked on 22 October 2026 against the 4 authorities it cites, for Australia.
Version
1
Source
Written for this library

When to use it

Adopt with the AML/CTF program and follow it when a matter closes or a system is culled. It does not authorise destruction of a document the firm must keep for a client file, a tax period, or a court order. Where two periods apply, keep the record until the last of them ends.

Used for these tasks

Each task page says how far AI may help with the task and what the lawyer must review.

How AI may be used

A tool may list records that are older than the period in this schedule and still sit in a folder, and a person decides whether any longer duty applies before anything is destroyed.

AI may

  • List files in the AML/CTF folder whose saved date is earlier than the destruction-not-before date calculated from this schedule.
  • Flag a file that has no matter close date, so a period that runs from the end of the relationship cannot be calculated.

AI must not

  • Must not delete a record, or move it to a rubbish folder.
  • Must not treat the AML/CTF period as overriding a longer client-file, tax or court requirement.
  • Must not include the contents of suspicious matter reports in a general destruction list sent to the whole firm.

The lawyer checks

  • The period used for each class matches the current Act, not only this schedule.
  • A person has checked that no longer hold applies before destruction.
  • Suspicious matter material and sanctions results are destroyed or retained only by the compliance officer's process, with access limited.

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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