---
title: "AML/CTF record retention schedule for the practice"
url: "https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/aml-record-retention-schedule"
type: "precedent"
site: "AI Law Framework"
id: "a52ob-aml-record-retention-schedule"
area_id: "A52OB"
kind: "policy"
ai_level: "yellow"
version: 1
task_ids: ["A52OB-X20260927-2", "A52OB-X20260927-3"]
law_stated_as_at: "2026-10-22"
---

# 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.

Canonical page: https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/aml-record-retention-schedule  
Law stated as at: 2026-10-22

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

## Key facts

- Kind: Policy. A policy or procedure for a firm or client.
- Practice area: [AML/CTF — the practice as a reporting entity](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity.md)
- Jurisdictions: Australia
- AI level: Yellow. You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at: 2026-10-22
- Status: Maintained. Checked on 2026-10-22 against the 4 authorities it cites, for Australia.

## 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](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/build-the-practice-s-risk-assessment-and-aml-ctf-policies.md)
- [Assemble the customer due diligence record before the service starts](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/assemble-the-customer-due-diligence-record-before-the-service-starts.md)

## 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.

## Authorities

- [AUSTRAC, Record keeping overview (program records, CDD records, retention periods)](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/develop-your-amlctf-programs/record-keeping/record-keeping-overview)
- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 26C (ML/TF risk assessment, including new or emerging technologies)](https://www.austlii.edu.au/cgi-bin/viewdoc/au/legis/cth/consol_act/alacfa2006522/s26c.html)
- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 28 (initial customer due diligence before a designated service starts)](https://www.austlii.edu.au/cgi-bin/viewdoc/au/legis/cth/consol_act/alacfa2006522/s28.html)
- [Privacy Act 1988 (Cth) Sch 1, APP 11.2 (destroy or de-identify when no longer needed, unless an Australian law requires retention)](https://www.oaic.gov.au/privacy/australian-privacy-principles/read-the-australian-privacy-principles)

## Official form

[Official form](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/develop-your-amlctf-programs/record-keeping/record-keeping-overview)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/aml-record-retention-schedule and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

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