What documents are mandatory?
AUSTRAC doesn't mandate a specific file structure, but a handful of documents and records are effectively mandatory for every reporting entity. Here's the full checklist, split into what's core policy and what's an ongoing register you keep updating.
Last updated 13 July 2026
Sound familiar?
- You're afraid you'll discover a missing register during an audit, not before it.
- Guidance mentions 'registers' and 'policies' interchangeably and you don't know if they're the same thing.
- You don't know which documents are strictly mandatory versus just good practice.
Core policy documents
- Written ML/TF risk assessment
- AML/CTF program (policy + process document)
- Compliance officer appointment record and AUSTRAC notification confirmation
Ongoing registers and records
- Customer due diligence records for every client (identity + beneficial ownership evidence)
- Staff due diligence records for personnel in AML/CTF-relevant roles
- Training completion register — who was trained, when, and on what
- Suspicious matter decision log — including matters considered but not reported, with reasoning
- Independent evaluation reports (at least once every 3 years)
Registers versus policy — what's the difference?
Policy documents describe how your business will operate (your commitments and procedures). Registers are the evidence trail that you actually did it — dated records showing training happened, ID was checked, and decisions were made. AUSTRAC audits look for both: the policy on paper, and the register proving it was followed.
Retention requirement
All CDD records, transaction records, and program documents must be kept for 7 years from the date the relevant service or record was created.
Coming soon
AML/CTF Document Generator
This interactive tool isn't built yet (planned component: DocumentGenerator). Check back soon, or read the guidance above in the meantime.
Where this leaves you
A complete, checkable list of every document and register AUSTRAC expects, so you can build against it directly.
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This is general information, not legal advice. Always verify current requirements on the AUSTRAC website or seek professional advice for your specific situation.