AML/CTF Tranche 1 Compliance Framework Bundle (Australia)

Policy, risk assessment & CDD tools for Australian reporting entities

$5,200.00 +GST

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A five-document AML/CTF compliance bundle for Tranche 1 reporting entities, combining an editable AML/CTF framework with practical risk assessment, customer due diligence, red-flag and onboarding tools.

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About this Document

Use this bundle if you:
  • Are a Tranche 1 reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
  • Need to document your AML/CTF Program, risk assessment and customer due diligence processes in one place
  • Want practical tools for onboarding, customer risk-rating, transaction monitoring and compliance reporting
  • Are preparing for internal governance approval, an independent review or an AUSTRAC review
  • Need a structured framework covering governance, CDD, enhanced CDD, PEP screening, sanctions screening and suspicious matter reporting
  • Want worked examples to help your team apply AML/CTF procedures consistently
  • Prefer a coordinated compliance document suite rather than separate templates developed in isolation
It is suited to:
  • AFSL holders providing securities, derivatives or foreign exchange-related designated services
  • Fund managers and responsible entities of managed investment schemes
  • Custodial and depository service providers
  • Reporting entities providing designated services under item 33 of table 1 in section 6 of the AML/CTF Act
  • Reporting entities that may also need to tailor their framework for items 29, 30, 35 or 46
  • AML/CTF Compliance Officers, compliance teams and governing bodies
  • Businesses updating their documentation for the AML/CTF Rules 2025 and Transitional Rules 2026
What this bundle covers:
  • An editable AML/CTF Framework Template covering governance, AUSTRAC enrolment, designated services, compliance roles and governing body oversight
  • Initial and ongoing customer due diligence procedures, including KYC collection, verification, simplified CDD and enhanced CDD
  • Customer risk assessment processes for individuals, companies, trusts, partnerships, SMSFs and other customer types
  • Politically exposed person, targeted financial sanctions, beneficial ownership and nested services considerations
  • Source of funds, source of wealth, intended transaction behaviour and customer risk-rating factors
  • An editable Business Risk Assessment Template covering customer, product, service, delivery-channel, jurisdiction, personnel, reporting and record-keeping risks
  • A Customer Risk Assessment Form with completed sample assessments for individual, SMSF and trust customers
  • An Initial CDD Matrix showing what information to collect, what to verify and how to verify it across customer types
  • An AML/CTF Red Flag Indicators Sheet with more than 100 completed sample indicators for customer due diligence and transaction monitoring
  • Worked sample responses, including further investigation, enhanced CDD, senior manager approval, refusal of service and AUSTRAC reporting
  • Suspicious matter reporting, international funds transfer instruction reporting, tipping-off, periodic compliance reporting and record-keeping considerations
  • Employee screening, AML/CTF training, outsourced service provider oversight and independent evaluation requirements
  • Practical cross-references between the framework, risk assessment and customer due diligence tools
You receive five editable documents:
  1. AML/CTF Framework Template – Tranche 1 Reporting Entities in Word format;
  2. AML/CTF Business Risk Assessment Template in spreadsheet format;
  3. AML/CTF Customer Risk Assessment Form – Completed Samples in spreadsheet format;
  4. AML/CTF Red Flag Indicators Sheet – Completed Samples in spreadsheet format; and
  5. Initial Customer Due Diligence Matrix Template in spreadsheet format.
Together, these documents provide a coordinated, lawyer-drafted starting point for documenting and implementing an AML/CTF framework. The examples, ratings and control measures must be reviewed and tailored to your entity’s designated services, products, customers, delivery channels, jurisdictions and governance structure before reliance. This bundle is not suitable for businesses whose only designated service is item 54, which may require a Special AML/CTF Program. It is not a substitute for tailored legal advice, a completed entity-specific risk assessment or an independent evaluation.

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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