Your ML/TF risk assessment and AML/CTF program, written for you
Answer guided questions about your business. Lead AML rates your risks, explains why, and writes your AML/CTF program from your answers, ready to approve and download. Included in every plan.
Step 1
ML/TF risk assessment
Ten short sections. Facts you’ve already given are filled in, and you can save and come back.
- Your business profile and sector
- The designated services you provide
- Service risks, with a written policy for anything you decline
- Delivery channels and technology
- Customer types
- Customer risks (PEPs, hidden ownership and more)
- Countries, with FATF and sanctions lists applied
- AUSTRAC enrolment
- Your controls, in place or planned
- Review and approval
Step 2
AML/CTF program
Unlocks once your risk assessment is approved. A few more questions, then the full program is written.
- Governance and senior management oversight
- Your AML/CTF compliance officer
- Outsourcing and reliance
- Personnel due diligence
- Staff training
- Monitoring and reporting to AUSTRAC
- Reviews, independent evaluation and record keeping
- Approval
What you get
Risk ratings with reasons
See inherent and after-controls risk for customers, services, channels, countries and operations, plus an overall Low, Medium or High rating, and why.
A full program, written for you
The AML/CTF program is written from your answers and your risk assessment, so the two always line up.
Approval built in
Your administrator approves each document, with a senior manager’s name and title on the signature block.
Versions kept
Changing an approved document starts a new version to approve; earlier versions stay viewable for your records.
Download as PDF
Print or save either document as a PDF whenever you need to share it or file it.
Help when you want it
Our CAMS-certified consultants can review your answers or build the program with you.
New to the obligations? Read our Tranche 2 guide or check whether you’re covered.
AML/CTF program FAQs
Do I need an AML/CTF program?
Yes, if you provide a designated service under Tranche 2. Every regulated business needs a written ML/TF risk assessment and an AML/CTF program, approved by senior management, setting out how it manages its money laundering and terrorism financing risks.
Is a generic AML/CTF program template enough?
A template is a start, but AUSTRAC expects the program to reflect your actual risks. That’s why Lead AML asks about your services, customers, channels, countries and controls first, then writes the program from those answers.
What’s the difference between the risk assessment and the program?
The ML/TF risk assessment identifies and rates your risks. The AML/CTF program sets out the policies, procedures and controls you use to manage them. In Lead AML the program unlocks once your risk assessment is approved, so it’s always built on it.
How often should I review them?
Review your risk assessment at least yearly, and whenever something material changes, such as a new service or customer type. Your program must also be independently evaluated at least every 3 years.
Is the builder included in my plan?
Yes. The risk assessment and AML/CTF program builder is included in every Lead AML plan, and you can try it free for 14 days with no card needed.
Is this legal advice?
No. The documents are built from your answers and are general in nature. If you want advice specific to your firm, our consultants can help.
Build your risk assessment and program today
- 14 days free, no card needed
- $50 of check credit to try ID and business checks
- Every Growth feature included