Policy · AML/CTF — the practice as a reporting entity
AML/CTF program for small legal practices: AUSTRAC legal profession starter kit adoption guide
Links to AUSTRAC's legal profession program starter kit and guides a small practice through checking suitability, customising the risk assessment, policy and process documents, approving the program, keeping it current and adding controls for AI tools.
- 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
- Link to the official form. Licence: CC BY 4.0 (© AUSTRAC for the Commonwealth of Australia 2026; excludes the AUSTRAC logo, the Commonwealth Coat of Arms and third-party material). Linked, with a short attributed summary of the suitability criteria.
Where this comes from
The official form is published by austrac.gov.au; this page is a completion guide. Last checked on 2026-10-17.
When to use it
Use if the practice provides designated services under Table 6 of s 6(5B) and meets AUSTRAC's suitability criteria (for example 15 or fewer personnel, mainly Australian individual clients). If it does not meet every criterion, the kit cannot be relied on as the program; build a tailored program, using the kit only as a reference.
How AI may be used
AI can help customise the kit from the practice's captured-services map and client profile, section by section, but the AML/CTF compliance officer directs the risk assessment and the senior manager approves the program.
AI may
- Draft customisations of the kit's risk assessment from the practice's own matter, client, channel and country data, for the compliance officer to review.
- Compare the customised documents with the latest kit release and change register and list sections needing update.
- Map kit forms to fields in the practice management system.
AI must not
- Must not rate the practice's ML/TF risks or accept risks on the practice's behalf.
- Must not adopt sector template ratings as the practice's own without the compliance officer's assessment.
- Must not be given client CDD records or suspicion information during customisation unless the tool is approved for that information.
The lawyer checks
- The practice meets every suitability criterion, or a tailored program is being built instead.
- The customised documents reflect the practice's actual services, clients, channels and countries, and the current kit release.
- The senior manager's approval and the date the program took effect are recorded.
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. Licence: CC BY 4.0 (© AUSTRAC for the Commonwealth of Australia 2026; excludes the AUSTRAC logo, the Commonwealth Coat of Arms and third-party material). Linked, with a short attributed summary of the suitability criteria..
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
- 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
- AI and automated tools in the AML/CTF program: control standard
- 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