AML/CTF Rules require senior management oversight of the program. For SMEs, this typically means a quarterly written report from the AMLCO to the directors or partners. Done well, it takes 90 minutes a quarter to produce and creates a clean audit trail of governance.
The five-section template
- Onboarding volume by risk tier — distribution and trends.
- Alerts and dispositions — number raised, closed, escalated to SMR.
- SMR/TTR filings — count, type, any AUSTRAC follow-up.
- Training currency — staff trained vs staff requiring training, attestation completeness.
- Open issues — anything from the last independent review or AUSTRAC engagement still outstanding.