Does this cover every obligation?
Before committing to any AML/CTF compliance product — or finalising a DIY setup — it's worth mapping it directly against AUSTRAC's actual obligations, one by one, rather than relying on a vendor's claim that they're 'covered'. Here's the checklist to verify against.
Last updated 13 July 2026
Sound familiar?
- You're about to commit budget and don't want to discover a gap during an actual AUSTRAC review.
- Vendor sales material is confident but you have no independent way to check the claims.
- You don't know what 'complete' would even look like to check against.
Obligation-by-obligation verification checklist
- Enrolment — does it help you complete AUSTRAC enrolment, or assume you've already done it elsewhere?
- Compliance officer — does it track the appointment and notification requirement, including re-notification if the officer changes?
- Risk assessment — does it produce a genuinely tailored assessment (your clients, services, channels, geography), or a generic template with your business name inserted?
- AML/CTF program — does the generated program cover all 6 minimum components: governance, risk assessment reference, ongoing CDD, third-party reliance, personnel due diligence and training, and independent evaluation?
- Customer due diligence — does it cover both initial verification and ongoing monitoring/re-verification triggers, not just onboarding?
- Record keeping and reporting — does it retain records for the full 7-year requirement, and does it support (or at least log) suspicious matter reporting decisions?
Independent evaluation still needs a human
No software can perform the independent evaluation AUSTRAC requires at least every 3 years — by definition, this must be conducted by someone other than the person responsible for running the program. Software can prepare you for that review; it can't replace it.
Red flag
If a vendor can't clearly show which of these obligations their product covers versus leaves to you, that's worth resolving before you commit — not after an AUSTRAC review.
Coming soon
Obligation Coverage Checker
This interactive tool isn't built yet (planned component: CoverageChecker). Check back soon, or read the guidance above in the meantime.
Where this leaves you
Confidence that a chosen product (or your own DIY setup) actually maps to every AUSTRAC obligation, verified against a checklist rather than taken on faith.
A lightweight AML platform, built exclusively for Tranche 2
Get AUSTRAC's mandates done as fast and effortless as possible.
- Built around AUSTRAC's actual requirements
- Single maintained compliance file
- No compliance expertise required
- 25 minute initial compliance setup
- Obligations calendar & reminders
- Instant data export
This is general information, not legal advice. Always verify current requirements on the AUSTRAC website or seek professional advice for your specific situation.