AML/CTF Process Document and Forms Template – Accountants (Tranche 2)

Australian accounting practices that provide designated services need more than a written AML/CTF policy — they need a consistent way to evidence what was checked, by whom and when. This template supplies the forms referenced throughout the Click Legal AML/CTF Policy (Accountants), covering personnel appointments, client onboarding and customer due diligence, escalation, and ongoing policy maintenance and reporting.

Use this template if you:

• Run an accounting practice with AML/CTF obligations under the Tranche 2 reforms
• Have adopted, or are adopting, an AML/CTF policy and need the supporting forms
• Want a documented audit trail for AUSTRAC, an independent evaluator or your governing body
• Need customer due diligence recorded consistently across client-facing personnel

It is suited to:

• Sole practitioners and single employee practices, including the conflict of interest variants
• Multi-partner firms allocating roles across a governing body, senior managers and personnel
• AML/CTF compliance officers building an evidence base ahead of independent evaluation
• Practices enrolling with AUSTRAC and maintaining their enrolment details

What this template covers:

• Part 1 personnel forms — roles, assigned responsibilities, personnel due diligence and a statutory declaration checklist
• Part 2 onboarding and CDD forms — identity verification, beneficial ownership mapping, PEP checks, DFAT sanctions checks, adverse media, and source of funds and wealth
• Part 3 ongoing review and escalation forms — trigger event reviews, periodic reviews, an escalation form and register, and unusual activity reporting
• Part 4 maintenance and reporting forms — policy update triggers, country risk ratings, effectiveness testing, independent evaluation responses, the annual governing body report and an AUSTRAC enrolment checklist
• Separate due diligence variants for the AML/CTF compliance officer and for single employee practices
• Risk-based periodic review frequencies of 12 months, two years and three years
• Enhanced due diligence triggers, with senior manager approval and conditions on continuing to act
• Tipping off reminders attached to the unusual activity review form

You receive 25 forms across four Parts as an editable Word document, with only [CLIENT NAME] and [Insert date] to complete before you tailor them to your own workflows. Reproducing the fields and steps in your existing systems is expressly contemplated. The forms are designed to be read with your AML/CTF Policy and Business Risk Assessment, and should be reviewed by a suitably qualified adviser against your circumstances before adoption.