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
- Build the practice's risk assessment and AML/CTF policies
- Assemble the customer due diligence record before the service starts
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.
Official form
Open the official form. Always use the current version from the issuer.
Read the full text
The full text is available after you log in. It is free. When you log 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
- AUSTRAC enrolment form for a reporting entity
- Independent evaluation of the practice AML/CTF program
- ML/TF risk assessment record for a legal practice
- Designated services capture map and enrolment decision record (AML/CTF Act s 6(5B), table 6)
- Enhanced customer due diligence decision record
- First independent evaluation deadline for the practice
- AUSTRAC suspicious matter report
- Customer due diligence file index before the service starts
- Initial customer due diligence checklist for law practice designated services
- AUSTRAC legal professional privilege form for a report
- Legal profession AML/CTF program review triggers
- AI and automated tools in the AML/CTF program: control standard
- Deadline to notify AUSTRAC of the AML/CTF compliance officer
- AUSTRAC legal professional privilege form for a notice
- Tipping-off holding script for staff and the approved client note
- 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