AML/CTF Red Flag Indicators Sheet Template

Aligned with AML/CTF Act red flag indicators

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Customer due diligence red flags table: transaction monitoring, risk assessment

About this Document

Use this Red Flag Indicators Sheet if you:
  • Provide securities, derivatives or structured products as designated services and want a worked example of red flag indicators
  • Are a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) building or updating your customer due diligence and transaction monitoring checklists
  • Want to see how each field is completed, including applicable flags, actions to take and risk ratings
  • Are training AML/CTF Compliance Officers, onboarding teams or transaction monitoring staff on recognising unusual customer behaviour
  • Need sample responses for escalation, enhanced CDD and suspicious matter reporting to AUSTRAC
It is suited to:
  • AFSL holders providing securities or derivatives designated services
  • Reporting entities whose business includes structured products
  • AML/CTF Compliance Officers and their delegates
  • Onboarding, KYC and transaction monitoring teams
What this sheet covers:
  • Initial customer due diligence red flags covering customer identification, behaviour, beneficial ownership and source of funds
  • Ongoing customer due diligence red flags for transaction monitoring and account activity
  • Securities and derivatives-specific indicators, including trading patterns and structured products
  • Columns for recording whether each indicator applies, the action taken and a Low/Medium/High risk rating
  • Worked sample action entries such as refuse customer, enhanced CDD, further investigation, senior manager approval and report to AUSTRAC
  • Risk assessment prompts to help you decide whether to update the Customer Risk Assessment Matrix
  • Over 100 completed sample indicators marked as applicable or N/A so you can model consistent customer reviews
You receive the Red Flag Indicators Sheet completed as a worked sample in spreadsheet format, showing how each indicator, action and risk rating can be recorded. It is a practical, lawyer-drafted reference for reporting entities producing their own sheet, leaving room for tailored legal advice in complex or high-risk 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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