Run AML/CTF customer due diligence
Set up your practice's AML/CTF program, mark designated services, and complete customer due diligence before the work starts.
- Set up
- Program
- Mark the job
- CDD
- Work starts
AML/CTF is Australia's anti-money laundering and counter-terrorism financing law. Some accounting work, called designated services, is now covered: think setting up a company or trust, helping sell a business, or handling client money. Before you provide one, you check who the client is. That check is customer due diligence (CDD).
Tax returns, BAS and bookkeeping on their own aren't designated services.
Who can do what?
- Anyone with the CDD permission can work on a client's CDD. Staff have it by default.
- Partners manage the program, the set-up, reporting to AUSTRAC, people and assurance.
- Only the senior manager named in set-up can approve the program or a high-risk client. Only they see the approve buttons. Everyone else sees who must approve.
- Suspicious matter reports are need-to-know. Only the firm owner sees them by default, and they can give that access to the compliance officer by name.
How do I set up the practice?
- Open ComplianceAML/CTF and choose Set-up.
- Tick the designated services you provide.
- Record your AUSTRAC enrolment (AUSTRAC is the regulator).
- Name the Governing body, the senior manager and the compliance officer. One person can hold all three.
- Under the compliance officer, choose Record assessment for their fit-and-proper check.
- Choose Save set-up.
How do I write the program?
- On the AML/CTF page, choose Start the program, then Start from the template.
- Rate each risk in the risk assessment, with a reason, and adapt the policies.
- Choose Save draft as you go.
- The senior manager chooses Approve as senior manager.
- Record the date you told the governing body in writing.
An approved version can't be changed. Changes go in a new version, which starts as a copy of the last one. The program shows when it's next due for review.
What does the AML/CTF page show?
The tiles count Clients needing CDD, Delayed CDD overdue, KYC reviews due and High-risk clients. Practice obligations lists what the practice still has to do, like enrolling, yearly reports and independent evaluations, each with its due date and a link to do it.
The Customer due diligence register lists every client with a CDD file. Use the tabs, like Needs CDD or Existing clients, and filter by risk.
How do I mark a job as a designated service?
On the client's WorkAML/CTF, under Jobs, pick the service beside the job. The job can't start until the client's CDD allows it. Once a designated service has started, its marking stays.
How do I do CDD for a client?
- On the client's AML/CTF section, choose Start CDD and pick the type of customer.
- Under People and entities covered, add the owners, controllers and anyone acting for the client. Billbook suggests people from the client's roles and holdings.
- Choose Verify identity… and Screen… for each person.
- Answer the Risk rating questions and choose Save rating.
- Under Who they are and why, fill in Nature and purpose of the service.
- If the rating needs enhanced CDD (high risk, a foreign politically exposed person or a high-risk country), fill in Source of funds, Source of wealth and Extra measures taken under Enhanced CDD, then choose Save.
- When everything under What’s needed is ticked, choose Complete CDD.
A high-risk client needs the senior manager to choose Approve… before any designated work starts.
How do I verify someone's identity?
Pick how you checked, like in person or on a video call with the photo matched, and the document you saw. Only the last few digits of the document number are shown, and no copy of the document is kept. Expired documents aren't accepted. Choose Save ID check.
How does sanctions screening work?
Everyone is checked against the DFAT Consolidated List, the government's sanctions list. Billbook re-screens every open file whenever the list changes. Choose Screen everyone to run it now.
A possible match shows a review button. Decide Not this person or It’s a match, with your reason. A confirmed match means you stop work on the client straight away.
How is the risk rated?
Any high-risk answer makes the client high risk. Two or more medium answers make them medium. Otherwise they're low. The rating sets how often you review their details. You can raise a rating for another reason with Raise the rating (other reasons), but never lower it below what the answers say.
What if I can't finish CDD before starting?
For a low-risk client, open the menu and choose Delay part of the CDD…. Say why the delay is essential and what's still outstanding. Sanctions screening can't be delayed. Billbook shows the date to finish by, and stops more work once it's overdue.
What about clients I had before the law started?
When you start CDD, tick that they're an existing client. Their file is marked as existing, and you can choose Start initial CDD now at any time, say when something changes.
How do I keep a client's details current?
Choose Record a review when a review is due or something changes, like new owners or a new designated service. Answer the risk questions again. The next review date resets from the new rating.
How do I decline or end a client?
From the menu, choose Decline to act… or, once CDD is complete, End the relationship…. Don't tell the client why if you suspect something, as that can be tipping off.
How do I report something unusual?
Anyone can choose Report unusual activity on a client's file, or Raise unusual activity under Reporting. It goes to the compliance officer, who decides whether there are grounds for suspicion.
If there are, they start a suspicious matter report. Billbook shows the deadline, keeps the draft and records every view. Lodge it in AUSTRAC Online, then enter the reference and choose Lodged in AUSTRAC Online.
Never put a tax file number in an AUSTRAC report. Billbook stops you saving text that looks like one.
What else is under Reporting?
- Threshold transactions: choose Record cash transaction for large physical cash the practice receives or pays out, then record it as lodged with its AUSTRAC reference.
- Annual report: the figures to help fill in the yearly compliance report, and where you record it lodged.
What are People and Assurance?
People tracks each staff member's due diligence check and training. Choose Record check or training, and Billbook shows when it's due again.
Assurance holds the compliance officer's reports (Record report) and independent evaluations of the program (Record evaluation), with their findings.
Can AML records be changed or deleted?
No. CDD files, ID checks, screenings, reviews and reports can't be deleted, and each client's AML/CTF record is a timeline that can't be edited. They're kept for the period the law requires, even after a client leaves.
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