
FAQs - Practical Compliance for Small Firms
How do I get started with AML compliance?
Start by understanding whether the services your firm provides are covered by Australia's AML/CTF regime and what obligations apply to your business.
Once you know you're in scope, focus on building and maintaining your AML/CTF framework. This includes conducting a Firm-Wide Risk Assessment (FWRA), developing your AML/CTF Program, implementing client due diligence processes, appointing and training your AMLCO, delivering staff training and meeting your reporting obligations.
AML Sorted can guide you through each step, whether you're starting from scratch or reviewing an existing framework.
What are the first things I need to do in respect of AML Compliance?
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Commence Data Collection: We have a FREE Data Collection Tool HERE.
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Conduct a Risk Assessment: Identify where and how your firm could be exposed to money laundering, terrorism financing or proliferation financing risks.
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Appoint a Compliance Officer: This person will oversee your AML/CTF Program.
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Create your AML/CTF Program: A written plan showing how you’ll meet your obligations (including client checks, training and reporting).
Can I outsource AML compliance?
Yes. You can engage external experts to help develop and maintain your AML/CTF Program, conduct independent evaluations, provide training and support your compliance function.
While some firms choose to outsource the AMLCO role, we generally recommend retaining that role within the firm and providing the AMLCO with the support they need to succeed.
AML Sorted can support almost every aspect of your AML/CTF compliance framework while helping your team remain in control of their obligations.
Do I need expensive software to comply with AML Compliance?
No. For most small firms, you don’t need costly systems to meet your obligations. Good record-keeping, clear procedures and the right advice are more important.
Tools like AML Sorted’s free data collection tool can make compliance much simpler without extra expense.
What if I can’t afford a Compliance Officer?
You must have someone responsible for compliance, but it doesn’t need to be a full-time role. In a small firm, the principal, director or practice manager may be able to undertake the role, provided they have sufficient authority, resources and time to oversee compliance effectively.
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