Checklist · AML/CTF — the practice as a reporting entity

Independent evaluation of the practice AML/CTF program

A checklist for an independent evaluation of a legal practice AML/CTF program: who may evaluate it, what they must be given, who receives the written report, and how adverse findings are answered.

Kind
Checklist. Steps or checks to work through and tick off.
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 authority it cites, for Australia.
Version
1
Source
Written for this library

When to use it

Use when the practice is arranging or answering an independent evaluation of its AML/CTF program. It is not the ML/TF risk assessment record, and it is not the starter-kit adoption guide.

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

AI may list documents already on the AML file and dates of earlier evaluations; the lawyer decides whether the evaluator is independent and how an adverse finding is answered.

AI may

  • List the risk assessment, the policies, and earlier evaluation reports that are already saved on the file
  • Enter the date the written report was received and the date it was sent to the governing body

AI must not

  • Must not decide that an evaluator is independent or suitable
  • Must not treat disagreement with a finding as a reason to skip the review the page requires
  • Must not invent a qualification the page says is not mandatory

The lawyer checks

  • The policies state how independence and suitability are decided, and the evaluator is not the compliance officer or a member of the compliance team
  • The written report goes to the governing body and to the senior manager who approves the program
  • Any update to the risk assessment or the policies is documented within 14 days after the update is made

Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.

Authorities

Read the full text

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