Notice · AML/CTF — the practice as a reporting entity
Tipping-off holding script for staff and the approved client note
Words the compliance officer approves for staff to use when more information is needed or a matter cannot proceed, so a client is not told that a suspicious matter report exists or that the practice is suspicious.
- Kind
- Notice. A formal notice to serve or publish.
- Where it applies
- Australia
- AI use
- Red You write the text. The tool writes nothing into the document. Where permitted, it may check, clarify or collect data, and anything it checks or collects is verified.
- 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
Adopt as part of the AML/CTF program and give it to anyone who speaks to clients about identification, source of funds, or ending a matter. A lawyer uses the s 123(4) path separately if the purpose is to dissuade a client from an offence. This script is not that advice.
Used for these tasks
- Decide what may be said to the client once a suspicion is reported
- Prepare the suspicious matter report
Each task page says how far AI may help with the task and what the lawyer must review.
How AI may be used
The compliance officer writes the words staff may say; a tool must not draft, vary or send any sentence that will be said or written to the client.
AI may
- Show the approved version number and the date, so staff can see whether they are looking at the current script.
- List staff names from the practice system who have not yet been marked as having read the current version.
AI must not
- Must not draft a reply to a client who asks whether they are under suspicion or have been reported.
- Must not explain s 123 to the client.
- Must not include the contents of a report, a suspicion, or a notice under s 49 or s 49B.
The lawyer checks
- Every sentence staff may say was approved by the compliance officer for this version.
- The script does not mention reports, suspicion, AUSTRAC lodgement, or "unusual activity".
- Staff who deal with clients have read this version, and the s 123(4) path is reserved to a lawyer.
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Official form
Open the official form. Always use the current version from the issuer.
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
- Customer due diligence file index before the service starts
- 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
- 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