--- title: "AML/CTF program for small legal practices: AUSTRAC legal profession starter kit adoption guide" url: "https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/amlctf-program-starter-kit" type: "precedent" site: "AI Law Framework" id: "a52ob-amlctf-program-starter-kit" area_id: "A52OB" kind: "policy" ai_level: "yellow" version: 1 law_stated_as_at: "2026-10-17" --- # 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… Canonical page: https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/amlctf-program-starter-kit Law stated as at: 2026-10-17 Site index for agents: https://ailawframework.com/llms.txt 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. ## 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. AI can help in set ways. A lawyer checks specific points before use. - Law stated as at: 2026-10-17 - Status: Maintained. Checked on 2026-10-17 against the official form at austrac.gov.au and the 7 authorities it cites, for Australia. ## 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. ## Authorities - [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ss 26C to 26K (ML/TF risk assessment, AML/CTF policies, governing body, compliance officer)](https://www.legislation.gov.au/C2006A00169/latest/text) - [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 6(5B), table 6 (professional designated services)](https://www.legislation.gov.au/C2006A00169/latest/text) - [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 51B (enrolment within 28 days after first providing a designated service)](https://www.legislation.gov.au/C2006A00169/latest/text) - [Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Cth)](https://www.legislation.gov.au/F2025L01026/latest) - [AUSTRAC, Legal profession program starter kit: Getting started (suitability criteria)](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/program-starter-kits/legal-profession-program-starter-kit/legal-profession-program-starter-kit-getting-started) - [AUSTRAC, Legal profession program starter kit: Document library](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/program-starter-kits/legal-profession-program-starter-kit/legal-profession-program-starter-kit-document-library) - [AUSTRAC, Updates to the legal profession program starter kit (release 1.1, 10 June 2026)](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/program-starter-kits/legal-profession-program-starter-kit/updates-legal-profession-program-starter-kit) ## Official form [Official form](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/program-starter-kits/legal-profession-program-starter-kit) ## 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. ## 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/amlctf-program-starter-kit 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.*