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What is an AML/CTF program (and how to write one)?
Last updated 8 September 2026
An AML/CTF program is the documented set of policies, procedures and controls your business uses to identify, manage and reduce money-laundering and terrorism-financing risk. AUSTRAC publishes a starter kit for each sector, which you adopt and tailor to your business.
What goes in an AML/CTF program
- A risk assessment of your business, customers and services.
- Policies and procedures for customer due diligence and screening.
- How you report suspicious matters and threshold transactions.
- Staff training, record keeping, and how the program is governed and reviewed.
How to write one
- Start from AUSTRAC's official starter kit for your sector.
- Complete the risk assessment for your actual business.
- Tailor the policies and processes to how you work, then have your compliance officer approve it.
Do I still need to tailor a template?
Yes. A template is a starting point, not a finished program. Your program has to reflect your real customers, services and risks, and you have to actually operate it day to day, which is where software helps.
Senly AML runs AUSTRAC's starter kit for your sector end to end, so your program is built, tailored and operated in one place.
Questions, answered.
- What is an AML/CTF program?
- It is the documented policies, procedures and controls your business uses to identify and manage money-laundering and terrorism-financing risk, built from AUSTRAC's starter kit for your sector.
- Can I just download a template?
- AUSTRAC's starter kit is the template. You still have to complete the risk assessment, tailor it to your business, and operate it day to day.
- Who approves the program?
- Your business appoints an AML/CTF compliance officer, and the program is approved and kept current under that governance.
This guide is general information, not legal advice. The official source is austrac.gov.au.