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

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.

Authorities

Official form

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

Read the full text

More in AML/CTF — the practice as a reporting entity

All precedents for AML/CTF — the practice as a reporting entity · Tasks and AI use in this area