Is the AML/CTF Program a true policy document with named key personnel and procedures as per AUSTRAC requirements?
Yes, the Program is a genuine policy document tailored to the firm's structure, sectors and risk levels, covering policies, procedures, governance and key personnel as AUSTRAC requires.
The platform's Automated Risk Assessment and Program Builder produces a genuine policy document - not a generic template - tailored to the business's structure, customer base, sectors, and risk levels. It's compliant with AUSTRAC's expectations for what an AML/CTF Program needs to include.
What the auto-generated Program covers:
- Policies - the firm's positions on customer acceptance, risk-rating, escalation, reporting, record-keeping, training, and ongoing monitoring.
- Procedures - the operational steps staff follow for CDD, screening, transaction review, suspicious matter assessment, and reporting.
- Systems and controls - the platform-level enforcement mechanisms (training gates, sign-off requirements, audit trails) that make the procedures binding rather than aspirational.
- Named roles - the Compliance Officer, 2IC, and key personnel are identified by role with their responsibilities mapped to specific Program sections.
- Sector-specific content - the Program incorporates the designated-services list, sector risk indicators, and sector-specific procedures relevant to the firm's actual business.
What makes it AUSTRAC-aligned:
- Built from a genuine Risk Assessment - not a generic template applied blindly. The Program reflects the firm's actual risk profile.
- Updateable as the business changes - new sectors, new services, structural changes trigger Program regeneration.
- Auditable evidence trail - the Program version history is preserved; the platform shows which version applied at any point in time.
- CO approval workflow - the Program is reviewed and accepted by the CO before activation, with the approval logged.
For customers who want to review the Program before subscribing, the freemium tier lets you complete the RA and view the auto-generated Program output - a strong way to assess whether the output meets the firm's expectations before committing.