Three months in, the hardest part of AML/CTF for most small practices is still the vocabulary. The obligations themselves are mostly common sense: know your client, notice when something is off, write it down. But they arrive wrapped in acronyms, and a receptionist who has never heard "ECDD" cannot be expected to know when it applies.
So here is the whole vocabulary on one page. Every term below is defined in one line, checked against AUSTRAC's own guidance, and linked to the AUSTRAC page it comes from and to our longer guide where we have one. Save the image, print it, stick it next to whoever opens new client files.
The Numbers to Remember
| Number | What it is |
|---|---|
| 25% | Ownership that makes someone a beneficial owner (AUSTRAC (opens in a new tab)) |
| $10,000 | Cash amount that triggers a TTR (AUSTRAC (opens in a new tab)) |
| 24 hours | SMR deadline if it relates to terrorism financing (AUSTRAC (opens in a new tab)) |
| 3 business days | SMR deadline for everything else (AUSTRAC (opens in a new tab)) |
| 10 business days | TTR deadline (AUSTRAC (opens in a new tab)) |
| 28 days | To appoint your compliance officer (AUSTRAC (opens in a new tab)) |
| 12 months | Compliance officer reports to the owner or board at least this often (AUSTRAC (opens in a new tab)) |
| 3 years | Review your risk assessment, and get an independent evaluation, at least this often (AUSTRAC (opens in a new tab)) |
| 7 years | How long you keep records (AUSTRAC (opens in a new tab)) |
| 30 Sep | Annual compliance report due. The first one covers 1 July 2026 to 30 June 2027 (AUSTRAC (opens in a new tab)) |
1. Am I In?
| Term | In one line | Go deeper |
|---|---|---|
| Designated service | An activity listed in the AML/CTF Act. Provide one and you are regulated. (AUSTRAC (opens in a new tab)) | Do I need to enrol? |
| Reporting entity | Anyone who provides a designated service. It is the service that counts, not your job title. (AUSTRAC (opens in a new tab)) | Sole traders |
| Tranche 2 | Lawyers, conveyancers, accountants, real estate, trust and company service providers, and dealers in precious metals and stones. Regulated since 1 July 2026. | Tranche 2 guide |
| Enrolment | Your business profile with AUSTRAC. The Tranche 2 deadline was 29 July 2026. (AUSTRAC (opens in a new tab)) | Missed 29 July? |
2. What You Must Have
| Term | In one line | Go deeper |
|---|---|---|
| AML/CTF program | Your ML/TF risk assessment plus your AML/CTF policies. Written, approved by a senior manager, in place before you provide the service. (AUSTRAC (opens in a new tab)) | Program walkthrough |
| ML/TF risk assessment | How criminals could misuse your business. Review at least every 3 years, sooner if your business changes. (AUSTRAC (opens in a new tab)) | Risk assessment template |
| Compliance officer | Management level, fit and proper, Australian resident. Appoint within 28 days, tell AUSTRAC within 14 days. (AUSTRAC (opens in a new tab)) | Compliance officer duties |
| Senior manager | Approves the risk assessment, the policies and every update, plus any foreign PEP customer. Cannot delegate this. (AUSTRAC (opens in a new tab)) | Governance roles |
| Governing body | The board, or in a small firm, the owner. (AUSTRAC (opens in a new tab)) | Governance roles |
| Starter kits | Free AUSTRAC program templates for small practices, one per industry. (AUSTRAC (opens in a new tab)) | Starter kit eligibility |
3. Every New Client
| Term | In one line | Go deeper |
|---|---|---|
| Initial CDD | Before you act, establish who the customer is, who acts for them, who owns them, and their risk. (AUSTRAC (opens in a new tab)) | CDD before you act |
| Beneficial owner | A person who owns 25% or more of the customer, or controls it. Follow the chain until you reach a human. (AUSTRAC (opens in a new tab)) | Beneficial owners |
| PEP | A politically exposed person. Foreign, domestic or international organisation, plus their family and close associates. (AUSTRAC (opens in a new tab)) | PEP or sanctions match |
| Sanctions | Check the customer and their beneficial owners against DFAT's Consolidated List. (AUSTRAC (opens in a new tab)) | PEP or sanctions match |
| Simplified CDD | Lighter checks for low-risk customers. Not an exemption. (AUSTRAC (opens in a new tab)) | Customer risk rating |
| Enhanced CDD | Mandatory extra checks for high risk, foreign PEPs, FATF high-risk countries, unusual transactions, or when you lodge an SMR and keep acting. (AUSTRAC (opens in a new tab)) | ECDD triggers |
| Source of funds | Where the money for this transaction came from. "My bank account" is not an answer. (AUSTRAC (opens in a new tab)) | Funds vs wealth |
| Source of wealth | Where the customer's whole wealth came from. (AUSTRAC (opens in a new tab)) | Funds vs wealth |
| Delayed CDD | Limited cases where you may start before CDD is finished, such as 20 business days. Real estate has its own timing. (AUSTRAC (opens in a new tab)) | Delayed CDD |
| Reliance | Using another reporting entity's CDD. Written arrangement, senior manager approval. (AUSTRAC (opens in a new tab)) | Relying on another firm |
4. After Onboarding
| Term | In one line | Go deeper |
|---|---|---|
| Ongoing CDD | Keep monitoring the customer and keep their risk and KYC information up to date. (AUSTRAC (opens in a new tab)) | After enrolment |
| Pre-commencement customer | A client you already had on 1 July 2026. No fixed CDD deadline. An SMR, or a significant change that makes them medium or high risk, triggers initial CDD. (AUSTRAC (opens in a new tab)) | Existing clients |
| Personnel due diligence | Vet staff in AML/CTF roles before they start and while they work for you. (AUSTRAC (opens in a new tab)) | Personnel due diligence |
| AML/CTF training | At the start of employment and on an ongoing basis. (AUSTRAC (opens in a new tab)) | Training requirements |
5. Reporting
| Term | In one line | Go deeper |
|---|---|---|
| SMR | Suspicious matter report. 3 business days after you form the suspicion, 24 hours for terrorism financing. (AUSTRAC (opens in a new tab)) | SMR guide with examples |
| TTR | Threshold transaction report. Cash of $10,000 or more, within 10 business days. (AUSTRAC (opens in a new tab)) | The $10,000 cash rule |
| Tipping off | A criminal offence to reveal an SMR where it could prejudice an investigation. (AUSTRAC (opens in a new tab)) | Tipping off |
| LPP form | For lawyers withholding privileged information from a report. (AUSTRAC (opens in a new tab)) | The LPP form |
| Annual compliance report | Covers the financial year. Lodge between 1 July and 30 September. (AUSTRAC (opens in a new tab)) | First compliance report |
6. Records and Checks
| Term | In one line | Go deeper |
|---|---|---|
| Record keeping | 7 years. You don't need copies of ID documents. Record what you checked. (AUSTRAC (opens in a new tab)) | What to keep, what to destroy |
| Independent evaluation | An independent review of your program, at least every 3 years. (AUSTRAC (opens in a new tab)) | Independent evaluation |
Three Pairs People Mix Up
Enrolment and registration. Every reporting entity enrols. Only remittance and virtual asset businesses also register, and cannot operate until AUSTRAC confirms it. (AUSTRAC (opens in a new tab)) An accounting practice enrols and is done.
Delayed CDD and pre-commencement customers. Delayed CDD is about new clients, and lets you start the service a short, fixed time before CDD is finished. Pre-commencement customers are the clients you already had on 1 July 2026, and they have no fixed deadline at all, only triggers. Different rules, different numbers.
Source of funds and "the bank account". AUSTRAC says it plainly: the source of funds is not where the customer transferred the money from, it is how they obtained it, such as salary or business income. (AUSTRAC (opens in a new tab))
Where AML Mate Fits
Most of this cheatsheet is a list of things to do once per client and remember forever after. In AML Mate the client file carries the CDD outcome, the beneficial owners, PEP and sanctions screening against DFAT's Consolidated List, the risk rating with its documented factors, and the next review date, so the terms above turn into fields someone has already filled in. The free compliance check takes about five minutes and shows which of the six sections your firm has covered.
This article is general information, not legal advice. For advice specific to your circumstances, consult a qualified AML/CTF professional.