Update on AML/CTF

Earlier this month we flagged amendments in the AML/CTF legislation which add obligations for us all when you deal with new and existing clients. This email updates progress in that area for you.

What is happening

This month, IFA-Aust begins implementation of its AML/CTF program. It’s not a “flip-the-switch” compliance event, it’s the start of embedding a new, consistent way of operating, for all advisers.

What this means for you

Starting this month, for all new client engagements you need to verify the client’s identity and record an AML/CTF risk score. Importantly:

• You do this at the time the client engages you (agrees to complete a terms of engagement).

• You don’t tell the client you are scoring them.

Policy guide

The AML/CTF policy guide has been updated with the new regulations and can be viewed in the portal via the Compliance --> Policies page. It explains:

• the background and the rules,

• shows you how to ID and ‘risk assess’ someone, and

• steps out the procedures if the event of a failed ID check or ‘high risk’ score.

Existing clients

There is no need to do a ‘bulk ID/risk assessment’ for all existing clients. Instead, you must apply the AML procedures when these circumstances arise:

• New money is invested

• Client structures change

• New advice is implemented

• Something appears unusual

Again, more information is available in the policy guide.

Suspicious matters: ID failures or high-risk assessments

You must escalate immediately if something does not make sense. What’s important is that you do not alert the client and you work with IFA and within the remit of the policy guide.

Where AML applies in your workflow

AML is required at particular points of financial activity, not every interaction:

Stage	AML Required
Initial phone call	No
At client engagement	Yes
Advice development	No
Implementation (products, new structures, additional funds)	Yes
Ongoing reviews	Trigger-based

What is NOT required (important)

You are not expected to:

• Re-identify all existing clients immediately

• Apply AML processes to purely strategic discussions

• Stop business while systems are embedded

What happens next

This is a transition period. Over the coming months:

• Processes will be refined

• Tools will be standardised

• Expectations will become fully embedded

Your role is to start applying the framework now, particularly for new client engagements plus implementation events for existing clients.

Your next steps

1. Read the guide.

2. If you have staff, talk to them and ensure they read the guide too.

3. Attend April's Safety & Success monthly meeting – this topic is on the agenda.

4. Don’t rush or panic!

This is new to us too. The 31 March 2026 deadline applies to AFSLs to have a fully redeveloped AMLCTF guide, a requirement which has been met. The next step is for you to start becoming familiar with the obligations, and develop & implement the appropriate workflows.