AML prep step-by-step

by | Dec 10, 2025 | AFSL, AML, KitLegal | 0 comments

Step 1 (now)

Work out if you will be regulated by AUSTRAC. If you do any of these things you will be:

Step 2 (now)

Consider your business structure. If you have only one entity providing designated services, that’s simple. That’s the entity that has to enrol with AUSTRAC and comply with all obligations. If you have more than one entity in your group that provides designated services, read here for more information about reporting groups and what you will need to do:

Step 3 (now)

Consider who you will appoint as your AML/CTF Compliance Officer. This is now a prescribed role with strict eligibility requirements. Refer to our AML/CTF Compliance Officer Checklist here:

Step 4 (now)

Consider who you will nominate as your ’Senior Manager(s)’. These are the people that need to approve your Risk Assessment and all AML/CTF Policies. They also need to approve relationships with certain high-risk customers and any arrangements where you are relying on customer due diligence undertaken by another entity enrolled with AUSTRAC. Refer to our AML/CTF Senior Manager Appointment Checklist here (note personnel due diligence will be required on this person and we have a separate checklist for this within the platform – those on our waitlist can ask for this in advance): 

Step 5 (now)

Work out how you are going to handle your AML/CTF obligations.

These include:

    • Documenting your business wide risk assessment (including documenting and ranking all of your money laundering, terrorism financing and proliferation financing risks)
    • Developing all of your AML/CTF policies – including policies, controls and compliance frameworks
    • Personnel due diligence and training
    • Initial and ongoing (including enhanced) customer due diligence
    • Reporting frameworks for all reporting obligations including SMRs
    • Record keeping

    If you engage Kit Legal, this is an easy one – we do ALL of the above for you in our Digital Compliance Platform which includes:

      • Fully customised AML/CTF risk assessment with supporting material

      • Fully customised AML/CTF policies
      • Required resolutions
      • Controls – including dynamic task list so no obligations are missed, attestations, declarations, registers, reports
      • Training modules to educate and upskill
      • Checklists, guides, templates
      • Regular webinars throughout the year with Q&A

    All content is kept up to date by Kit Legal as laws and AUSTRAC guidance changes.

    *We do not include an ID (identity verification) service as we don’t want to be aligned to any one product. Our clients like flexibility to choose their own ID provider (if they want one) or do identity verification manually depending on what is best for their business.

    We deliver all of the above for a monthly subscription of $300 ex GST. Join our waitlist here: AML/CTF Product waitlist (we will be onboarding on a first in best dressed basis).

    Joining the waitlist means you will be sorted for everything related to AML and can relax. We will be in touch to onboard you in the new year and will keep you updated and provide further material during January so you can have all staff trained and ready to go from the due date. 

    Register for our free webinar series here for detailed training in the lead up to March: Webinar registration

    Step 6 (Jan/Feb 2026)

    Consider whether you want to use identity verification software. Read more about electronic verification here:

    Step 7 (March 2026)
    New entities will enrol with AUSTRAC from 31 March. Those clients who have signed up for our product will have detailed guidance on how to do this.
    Step 8 (March – June)
    Ensure everything is set up and all staff are trained and ready to go from 1 July 2026. Again, if you’re on the waitlist, this is sorted. The self-serve training modules within our product include:
      • Role and obligations of AML/CTF Compliance Officer
      • Role and obligations of Senior Manager
      • Role and obligations of Governing Body
      • Dealing with PEPs
      • Initial Customer Due Diligence
      • Ongoing Customer Due Diligence
      • Enhanced Customer Due Diligence
      • Personnel Due Diligence and Training
      • Record Keeping Obligations
      • General Reporting Obligations
      • Suspicious Matter Reporting
      • Reporting Groups
      • Outsourcing
      • Relying on other entities for customer due diligence
      • Risk assessments