---
title: "Tipping-off holding script for staff and the approved client note"
url: "https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/tipping-off-holding-script"
type: "precedent"
site: "AI Law Framework"
id: "a52ob-tipping-off-holding-script"
area_id: "A52OB"
kind: "notice"
ai_level: "red"
version: 1
task_ids: ["A52OB-X20260927-6", "A52OB-X20260927-5"]
law_stated_as_at: "2026-10-22"
---

# 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.

Canonical page: https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/tipping-off-holding-script  
Law stated as at: 2026-10-22

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

## Key facts

- Kind: Notice. A formal notice to serve or publish.
- 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: 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: 2026-10-22
- Status: Maintained. Checked on 2026-10-22 against the 3 authorities it cites, for Australia.

## 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](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/decide-what-may-be-said-to-the-client-once-a-suspicion-is-reported.md)
- [Prepare the suspicious matter report](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity.md#A52OB-X20260927-5)

## 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.

## Authorities

- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 123 (tipping off)](https://www.austlii.edu.au/cgi-bin/viewdoc/au/legis/cth/consol_act/alacfa2006522/s123.html)
- [AUSTRAC, Tipping off (s 123, customer management, scripts and genuine reasons)](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/reporting-us/tipping-off)
- [Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 28 (initial customer due diligence before a designated service starts)](https://www.austlii.edu.au/cgi-bin/viewdoc/au/legis/cth/consol_act/alacfa2006522/s28.html)

## Official form

[Official form](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/reporting-us/tipping-off)

## 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/tipping-off-holding-script 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.*