AML/CTF Business Risk Assessment Template (Australia)

For Australian reporting entities under the AML/CTF Act

$1,600.00 +GST

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Use this template to:
  • Identify ML/TF risks across customers, services, channels and jurisdictions;
  • Rate each risk by likelihood and impact for scoring;
  • Assign control measures to mitigate each identified risk;
  • Document how you consider and record AUSTRAC feedback.

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Jurisdiction Risk Rating table: AML/CTF, FATF classification, sanctions, and risk levels.

About this Document

Use this template if you:
  • Are a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and need a documented business risk assessment
  • Want a structured, AUSTRAC-aligned way to identify, rate and control money laundering and terrorism financing (ML/TF) risks
  • Need to assess risk across customer types, designated services, delivery channels, jurisdictions and internal practices
  • Prefer a tabbed spreadsheet you can tailor to your industry and delete the sections that do not apply
  • Are preparing for an AUSTRAC review, independent review or governing body reporting
It is suited to:
  • Reporting entities under the AML/CTF Act
  • Businesses providing designated services such as dealing in securities, derivatives or foreign exchange, managed investment schemes, or custodial and depository services
  • Reporting groups that need to consider risks across all entities in the group
  • AML/CTF Compliance Officers and compliance teams preparing and reviewing the assessment
What this template covers:
  • A general risk assessment tab relevant to all reporting entities, plus industry-specific tabs you can keep or delete
  • Risk identification across customer types, designated services and products, delivery methods and channels, and jurisdictions
  • Likelihood and impact ratings requiring review at least every 12 months
  • Customer profile risks, including individuals and sole traders, third parties acting for customers, and politically exposed persons or sanctions matches
  • Product, service and delivery-channel risks, including securities and derivatives, managed investment schemes, custodial services and remote onboarding
  • A jurisdiction risk rating tool covering Australia and low, medium and high-risk foreign jurisdictions
  • Internal business practice and reporting risks, including AUSTRAC enrolment and registration, suspicious matter reports and IFTIs, personnel training and record keeping
  • A register to evidence consideration of AUSTRAC communications and feedback, with control measures for each rated risk
You receive an editable Business Risk Assessment in spreadsheet format, pre-populated with example risks, ratings and control measures based on AUSTRAC guidance, plus prompts to tailor risk factors and review frequency to your organisation. The examples are intended as a practical, lawyer-drafted starting point rather than a comprehensive risk register, so you should still review and tailor them to your business, and seek advice for complex or unusual scenarios.

How To Use This Template

This template is a starting point, not a final document. It’s been drafted by Australian lawyers to be practical and flexible, but it still needs to be reviewed and tailored for your specific business, transaction and risk profile.

Before you use it, you should:

  • Complete all placeholders, bracketed items and optional fields;
  • Remove any drafting notes or clauses that aren’t relevant to your situation; and
  • Check that party names, entity details, dates, addresses, contact details and defined terms are accurate.

Make sure the template is consistent with your other documents and obligations – including any existing contracts, policies, procedures, website terms, privacy disclosures, regulatory requirements or internal governance documents. If anything conflicts, it should be resolved before you sign, issue, adopt or implement the document.

If you are using the template as an agreement, it should be reviewed and signed by all relevant parties in accordance with applicable law and your internal signing requirements. If you are using it as a policy, procedure, notice or compliance record, it should be approved and stored under your organisation’s normal document control processes.

This template is provided as general information only and is not legal advice. Complex, high‑value, highly regulated or cross‑border matters will usually require bespoke drafting. For anything outside a straightforward use case, we strongly recommend obtaining legal advice before relying on, signing or implementing this document.

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