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

Suspicious matter escalation, reporting and legal professional privilege procedure

Procedure from internal escalation to lodgement of a suspicious matter report: when the obligation arises, the 24-hour, 3 and 5 business day deadlines, privilege review and LPP forms, what AI may and may not do, client communications and tipping off.

Kind
Policy. A policy or procedure for a firm or client.
Where it applies
Australia
AI use
Red Keep AI out of the decisive steps. A lawyer does the work.
Law stated as at
17 October 2026
Status
Maintained. Checked against the cited sources on 17 October 2026.
Version
1
Source
Written for this library

When to use it

Adopt as part of the AML/CTF program of any practice providing designated services. Use whenever a staff member notices unusual activity, CDD cannot be completed, or a client's instructions raise a concern. It is lawyer-led throughout.

How AI may be used

Lawyer-led. AI may index the file into a dated chronology and compare the practitioner's completed text against the file for dates, amounts and names, inside a controlled environment, but it writes no part of the report or of anything said to the client.

AI may

  • Index the file into a dated chronology of instructions, transactions, communications and documents for the practitioner to read.
  • List the report fields for which the file holds no source.
  • Compare the practitioner's completed text against the file for dates, amounts, names and account details.

AI must not

  • Must not write any part of the SMR, the grounds of suspicion, an LPP form or any client communication.
  • Must not decide whether a suspicion is held on reasonable grounds, whether information is privileged, or what the client is told.
  • Must not operate outside the practice-controlled environment approved by the compliance officer.

The lawyer checks

  • The time the suspicion was formed is recorded and the correct deadline applied.
  • Privilege has been assessed item by item, with the basis recorded and independent advice sought where in doubt.
  • No disclosure has been made that could tip off, and everyone who knows of the escalation is listed.

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

Authorities

Official form

Open the official form. Always use the current version from the issuer.

Read the full text

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