---
title: "Legal profession AML/CTF program review triggers"
url: "https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/program-review-trigger-register"
type: "precedent"
site: "AI Law Framework"
id: "a52ob-program-review-trigger-register"
area_id: "A52OB"
kind: "checklist"
ai_level: "yellow"
version: 1
task_ids: ["A52OB-X20260927-2"]
law_stated_as_at: "2026-10-22"
---

# Legal profession AML/CTF program review triggers

> A register of the events AUSTRAC's legal-profession maintain-and-review page says should trigger a review of the practice program, and the process or form that page names for each event.

Canonical page: https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/program-review-trigger-register  
Law stated as at: 2026-10-22

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

## Key facts

- Kind: Checklist. Steps or checks to work through and tick off.
- 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 authority it cites, for Australia.

## When to use it

Use when something changes in a small legal practice that adopted the AUSTRAC legal profession starter kit, and the question is whether the program now has to be reviewed. It is not the risk assessment itself and it is not the kit's adoption guide.

## 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)

## How AI may be used

AI may open a row when the lawyer records a change of service, client type, country, or an incident; the lawyer decides whether the program is updated and what is told to staff.

**AI may:**

- Open a row using one of the trigger labels on the maintain-and-review page
- List the process and form names the page gives for that trigger

**AI must not:**

- Must not decide that a risk remains inside the practice's risk appetite
- Must not fill in the starter-kit forms from this register
- Must not treat a starter-kit update as adopted until the practice has decided to incorporate it

**The lawyer checks:**

- The trigger matches a row on the page, including a change in technology used to provide a designated service
- An adverse evaluation finding is marked to be addressed as soon as practicable, as that row states
- Staff who must use an updated control are identified, and training is recorded if the page's review step requires it

## Authorities

- [AUSTRAC, Step 3: Maintain and review your legal profession program, last updated 2 April 2026: review triggers and the forms named for each trigger](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/program-starter-kits/legal-profession-program-starter-kit/step-3-maintain-and-review-your-legal-profession-program)

## 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/program-review-trigger-register 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.*