Checklist · AML/CTF — the practice as a reporting entity
Customer due diligence file index before the service starts
Index of the s 28(2) matters against the documents on the file, completed before a designated service starts, so a missing identity, authority, beneficial owner or sanctions check is visible.
- Kind
- Checklist. Steps or checks to work through and tick off.
- Where it applies
- Australia
- AI use
- Green The tool writes the first draft inside a template you have already tested. You check it. Without that test, first drafting starts at Yellow.
- Law stated as at
- 22 October 2026
- Status
- Maintained. Checked on 22 October 2026 against the 3 authorities it cites, for Australia.
- Version
- 1
- Source
- Written for this library
When to use it
Use on each matter that is a designated service, before the service starts. It shows whether the file contains material for each s 28(2) matter. The compliance officer or the responsible lawyer still decides whether that material establishes the matters on reasonable grounds.
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
Inside this fixed index, an approved tool may enter the document title and date already saved on the file for each s 28(2) row, and the lawyer confirms the row before the service starts.
AI may
- Enter the filename and date of a document already stored against the matching s 28(2) row.
- Leave a row blank and mark it "no document on the file" when the file has none.
- List rows that are still blank.
AI must not
- Must not tick "established on reasonable grounds".
- Must not treat a screening vendor's "pass" as verification under s 28(3)(d).
- Must not start the designated service, or tell the client that it has started.
The lawyer checks
- Each document named is the document on the file, and it relates to this client.
- The reasonable-grounds column is completed by a person, for every row, before the service starts.
- If a s 32 trigger is present, the enhanced due diligence decision record is attached and the service has not started ahead of it.
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
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
- 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
- AML/CTF record retention schedule for the practice
- 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