What To Do If Your AML Program Is Too Complicated
Casey Cossu
Your AML platform generated a program you don’t understand? The short answer: you’re not stuck with it. You can adopt a simpler replacement — via the AUSTRAC starter kit or a custom program — as long as it covers the required elements, you retrain your staff, get senior manager approval and document the change.
A lot of agencies may use their AML/CTF platform’s auto-generated program as a quick way to get something in place before the 1 July 2026 deadline. That’s a sensible starting point. But if you’ve now read it back and found it dense, generic, or genuinely hard to apply to how your agency actually operates, the good news is you’re not stuck with it.
There’s no rule that says your AML/CTF program has to be whatever your platform first generated. That version was a template, built to cover the regulatory bases for a broad range of businesses. It may not reflect your agency’s actual structure, risk profile, or day-to-day processes. If it doesn’t work for your business, you’re entitled to replace it with a program that does.
A program nobody can follow because it’s too complex or generic isn’t actually protecting you and may potentially fall short of your compliance obligations.
Can You Replace Your AML/CTF Program?
You can write or commission a new AML/CTF program to replace the one you currently have, as long as it still covers the required elements.
The new version can be simpler in language and structure than the platform’s original, provided it still substantively addresses your obligations.
What Are Your Options for a Replacement Program?
Download the AUSTRAC real estate starter kits and work through the customisation process. It does take some time to work through the starter kits and can be difficult if you’re not familiar with the legislation. The AUSTRAC program is designed to be simple and may be the easiest to implement in your business.
Get a custom AML program designed for your business. The time and cost associated with this option may vary depending on your provider.
You’ll Need to Retrain Staff on the New Program
Changing your AML/CTF Program isn’t just a document swap. If your processes, escalation steps or workflows have changed in any meaningful way, your staff need to be retrained on the new version before they’re relying on it. This includes agents, sales support, and admin staff who touch any part of the customer due diligence or escalation process, not just your compliance officer.
Keep Records of the Change and Get It Approved
Two things need to happen and be documented when you swap programs:
Senior management approval. Your AML/CTF program must be approved by the designated Senior Manager. If you’re adopting a new program, that approval needs to happen again for the new version. Ensure the approval is in writing and file it with your compliance records.
A record of the change itself. Keep a clear record showing what the old program said, what the new one says, when the change was made, why it was made, and who approved it. This becomes part of your audit trail — if AUSTRAC ever asks how your program has evolved, you want to be able to show a considered, approved change rather than an undocumented swap. Ensure the version control is updated accordingly.
Disclaimer
This article is provided for general informational purposes only and does not constitute legal advice. It reflects a general summary of publicly available guidance and is not a comprehensive or authoritative interpretation of the Anti-Money Laundering and Counter-Terrorism Financing Act, associated Rules, or any other legislation. Laws, regulations and regulatory guidance can change, and how they apply will depend on your specific circumstances. Before acting or relying on any information contained in this article, you should seek independent advice tailored to your situation.
