Preview questions in the AUSTRAC 2023 compliance report
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If you are unable to access AUSTRAC Online to complete your compliance report, please call the AUSTRAC Contact Centre on 1300 021 037.
The information on this page will help you complete your 2023 compliance report.
Your 2023 compliance report will cover your business activities for the 2023 calendar year.
When your report is due
Your 2023 compliance report must be submitted to AUSTRAC between 1 January and 31 March 2024. There can be penalties for failing to submit your compliance report. Find out more about the consequences of not complying.
2023 compliance report questions
The questions in the 2023 compliance report are listed below to help you prepare. We’ve made changes to some questions this year to make it easier for you to complete your report.
An explanation of the bolded terms can be found under ‘key terms’. Further information can be found by clicking the linked text.
Preview questions
| Questions | Key terms |
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| Did you offer designated services during all or part of the reporting period (1 January 2023 00:00 to 31 December 2023 23:59)? (Yes or No) | |
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If Yes Do you believe you have a legal exemption from submitting a compliance report? (Yes or No) If Yes On what basis do you believe this? (Maximum 500 characters) |
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If you did not offer designated services (you will only be presented with the Your feedback and Review and submit sections of the form): Are you sure? You have been enrolled as providing designated services during this period.
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| Why did your business not offer designated services during all or part of the reporting period? (Maximum 500 characters) | |
| Does your business intend to offer designated services in 2024? (Yes or No) | |
| Does your business provide digital currency exchange services? (Yes or No) |
Digital currency exchange services Providing a digital currency exchange service means exchanging money (whether Australian or foreign currency) for digital currency, or exchanging digital currency for money (Australian or foreign currency). |
| Does your business accept/trade in cash? (Yes or No) | |
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Does your business offer any of the following products and/or services? (Select all that apply)
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| Does your business accept customers from overseas jurisdictions? (Yes or No) | |
| What transaction amounts and/or limits does your business apply to the amount of fiat and/or digital currency for buy/sell/trade orders? (Maximum 500 characters) | |
| Did your business utilise blockchain technology in 2023? (Yes or No) | |
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If Yes What type of blockchain tools did your business use in 2023? (Select all that apply)
If other please provide details (Maximum 200 characters) |
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What did you use these block-chain technologies for? (Select all that apply)
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| Did your business experience de-banking in 2023? (Yes or No) |
Debanking De-banking means a situation in which a financial institution withdraws banking services to a business. AUSTRAC understands there is industry-wide concern due to the risk of de-banking. Information provided under this question will only be used to help AUSTRAC establish a picture of the extent of this concern. |
| Did you acquire or merge with another entity in 2023? (Yes or No) | |
| Did you acquire or merge with another Reporting Entity in 2023? (Yes or No) | |
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If Yes Please specify the nature of the merger/acquisition? (Maximum 500 characters) |
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Approximately how many full time equivalent employees does your business have?
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Employee A person who is employed and paid through wages or salary or under contract. |
| If 200 or more, please provide details (Maximum 100 characters) | |
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Approximately how many of those full time equivalent employees have a primary role in AML/CTF compliance?
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| Please specify number of full time equivalent employees with a primary role in AML/CTF compliance (Maximum 6 characters) | |
| Has there been a change in key personnel or contact details for your business? (Yes or No) |
Key personnel For remitters and digital currency exchange providers – key personnel means beneficial owner(s), director(s), AML/CTF compliance officer or any other individuals who have the ability to influence business decisions over the entity’s finances and operations. For all other enrolled entities that DO NOT provide either remittance or digital currency exchange services – key personnel means the AML/CTF compliance officer. |
| Have you notified AUSTRAC of these changes? (Yes or No) | |
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How did you provide designated services in 2023? (Select all that apply)
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Designated services IDM Intelligent Deposit Machine, a type of advanced ATM that offers self-service transaction facilities which credits cash and cheque deposits to recipient accounts. Mobile application Is software, often called an 'App', designed to run on a mobile device, such as a smartphone or tablet. Remittance platform A system that enables funds transfers for remittance purposes. If you are a remittance network provider, whose affiliates conduct transactions using your remittance platforms, you MUST select this option. Self-service gambling terminal A terminal at which customers can credit or withdraw from an account or place a bet or wager. Self-service gambling terminal does NOT include an electronic gaming machine. Additional method(s) Select this option if you provided designated service(s) using methods other than, or in addition to, those that are listed. If you enter more than one 'Additional method', please separate them with a comma. |
| Were any of the above delivery methods introduced in 2023? (Yes or No) |
Delivery methods Channels through which your business provides or delivers the designated services. |
| Why were these delivery methods introduced in 2023? (Maximum 500 characters) | |
| Did your business conduct an ML/TF risk assessment on the new delivery methods introduced in 2023? (Yes or No) | |
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If No Why did your business not conduct an ML/TF risk assessment for the new delivery method? (Maximum 500 characters) |
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Which delivery methods were introduced in 2023? (Select all that apply)
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Outsourcing |
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Did your business outsource any of the following AML/CTF functions in 2023? (Select all that apply)
Please see AUSTRAC’s guidance on Engaging AML/CTF advisors. |
Outsourcing AML/CTF compliance functions For the purposes of the Compliance Report, ‘Outsourcing’ is considered to be: Entering into an agreement with a third party to undertake aspects of the AML/CTF program on your behalf.
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| Have you confirmed that your outsourced program is tailored to your business and its ML/TF risks? (Yes or No) | |
| Legal business name of the provider for your AML/CTF program development? (Maximum 200 characters) | |
| Legal business name of the provider for your outsourced customer identification? (Maximum 200 characters) | |
| Legal business name of the provider for your outsourced transaction monitoring? (Maximum 200 characters) | |
| Legal business name of the provider for your outsourced transaction reporting? (Maximum 100 characters) | |
| How does your business monitor and manage its outsourced AML/CTF function(s)? Please provide details of any due diligence, governance or assurance programs in place. (Maximum 500 characters) | |
| Do you have an AML/CTF program? (Yes or No) |
AML/CTF program Sole trader or individual If your business operates as a sole trader or an individual, you are still required to have an AML/CTF program. |
| What was the reason for not having an AML/CTF program (Maximum 200 characters)? |
AML/CTF program Explain why you do not have an AML/CTF program. |
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When was your AML/CTF program last approved?
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AML/CTF program approval Approved program Approved means adoption of the initial program or approval of changes to your program by your board, senior management or equivalent. Sole Trader If your business operates as a sole trader or an individual, then the sole trader or individual will need to approve the program. Governing Board If your business does not have a governing board, then your senior management will need to approve the program. |
| Why has the AML/CTF program not been approved? (Maximum 500 characters) | |
| Did you make any changes to your AML/CTF program in 2023? (Yes or No) | |
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What prompted these changes? (Select all that apply)
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Changes to AML/CTF Program The events that prompted changes to the program, may have occurred outside of the reporting period. Media Reports Reports include, but are not limited to, newspaper articles, news websites, social media. Additional reason(s) Select this option if you have reasons other than, or in addition to, the reasons that are listed. If you enter more than one ‘Additional reason’, please separate them with a comma. |
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When was Part A of your program most recently independently reviewed?
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Please see AUSTRAC's guidance on Engaging AML/CTF advisors |
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Why has your program not been independently reviewed? Enter reason below (Maximum 500 characters) |
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How often does your AML/CTF program state that your Part A AML/CTF program must be independently reviewed? Tick the most appropriate option.
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| Why does your program not specify a frequency? (Maximum 500 characters) | |
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What prompted this review? (Select all that apply)
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Reasons for review The events that prompted this review. These may have occurred outside of the reporting period. Media Reports Reports include, but are not limited to, newspaper articles, news websites, social media. Additional reason(s) Select this option if you have reasons other than, or in addition to, the reasons that are listed. If you enter more than one ‘Additional reason’, please separate them with a comma. |
| What additional reasons prompted the independent review? (Maximum 500 characters) | |
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How was the independent review conducted?
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Service provider type
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Service provider name Legal business name of the provider (Maximum 100 characters) |
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Did you report internally to the Board or Senior Management on any of the following matters in 2023? (Select all that apply)
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Reporting internally Means informing your board, senior management or equivalent through a recorded notification (e.g. email, written brief, attendance at a minuted meeting.) Other matter(s) Select this option if you reported on any other matter(s) other than, or in addition to, the matters that are listed. If you enter more than one ‘Other matter’, please separate them with a comma.
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| Did you conduct an ML/TF risk assessment of your business in 2023? (Yes or No) |
ML/TF ML/TF means money laundering and terrorism financing. |
| Was this risk assessment documented? (Yes or No) | |
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What prompted this risk assessment? (Select all that apply)
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Reasons for risk assessment Media Reports Reports include, but are not limited to newspaper articles, news websites, and social media. Additional reason(s) Select this option if you had reason(s) other than, or in addition to, the reasons that are listed. If you enter more than one 'Additional reason', please separate them with a comma. |
| Do you have a documented process for conducting a risk assessment? (Yes or No) | |
Assessment |
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What employee checks do you conduct? (Select all that apply)
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Employee Check Third party providers You have also conducted a check if you use a third party provider for employee due diligence. Select the checks that they undertake on your behalf. Open source searches Information searches using publicly available sources on the internet. PEP A PEP is a politically exposed person. Social media review Information searches on social network online platforms. Additional check(s) Select this option if you conducted checks other than, or in addition to, those that are listed. If you enter more than one ‘Additional check’, please separate them with a comma. |
| Do you assess the ML/TF risk for each employee’s role? (Yes or No) |
ML/TF ML/TF means money laundering and terrorism financing. |
| Do you conduct different employee checks for roles with higher ML/TF risk? (Yes or No) | |
AML/CTF Training |
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| Did you provide AML/CTF training in 2023? (Yes or No) | |
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What AML/CTF training did you provide? (Select all that apply)
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AML/CTF training type Additional training Select this option if you provided training other than, or in addition to, the types that are listed. If you enter more than one ‘Additional training’, please separate them with a comma. |
| Did you update your AML/CTF training program in 2023? (Yes or No) |
Updates to AML/CTF training program Includes changes to the content of training, the way in which training was delivered, who it was delivered to, or how frequently it was delivered. |
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What prompted this update? (Select all that apply)
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Updates to AML/CTF training program Includes changes to the content of training, the way in which training was delivered, who it was delivered to, or how frequently it was delivered. Media Reports Reports include, but are not limited to newspaper articles, news websites, and social media. Additional reason(s) Select this option if you had reason(s) other than, or in addition to, the reasons that are listed. If you enter more than one 'Additional reason', please separate them with a comma. |
Customers |
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Approximately how many customers/members do you have?
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What are your customer types? (Select all that apply)
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Customer Types These are the types of customers that you provide designated services to. |
Customer verification |
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Risk assessment |
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How many of your customers are high risk or above? Number of customers (Maximum 6 characters) |
High risk customer You are required to assess what you consider to be a high risk customer relationship within your business. This assessment should be set out in your AML/CTF program. Factors that you should take into account include:
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| What factors do you consider when determining a customer as high risk? (Maximum 500 characters) | |
| Did you perform Politically Exposed Persons (PEPs) checks in 2023? (Yes or No) |
Politically Exposed Persons (PEPs) Where your business uses a broader PEP definition than that prescribed by the AML/CTF Act, you may choose to answer based on that definition. |
| Why did you not perform PEP checks in 2023? (Maximum 500 characters) | |
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How did you identify PEPs? (Select all that apply)
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Politically Exposed Persons (PEPs) identification Where your business uses a broader PEP definition than that prescribed by the AML/CTF Act, you may choose to answer based on that definition. Open source searches Information searches using publicly available sources on internet. Commercial database A database of information developed and maintained by a commercial entity and made available to customers. This is the information for which you are likely to pay or subscribe for. Additional method(s) Select this option if you identify PEPs using methods other than, or in addition to, the methods that are listed. If you enter more than one 'Additional identification method', please separate them with a comma. |
| How many of your customers did you identify as PEPs? Number of customers (Maximum 6 characters) | |
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How many of your customers were on record as PEPs in 2023? Select all that apply
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| Does your business obtain Applicable Customer Identification Information provided by brokers? (Yes or No) |
A Broker is a person that facilitates transactions (including provision of information) between parties. This includes instances where a reporting entity, for example a financial institution provides designated services to a customer who may first be introduced to the financial institution through a broker (for example, finance/mortgage broker). This question is seeking to understand whether the reporting entity obtains applicable customer identification information that may have originally been obtained by the broker in the course of their engagement with a customer. |
| Does your business verify the Applicable Customer Identification Information provided by brokers? (Yes or No) | This question seeks to understand in instances where information is provided by the broker to the reporting entity, whether the reporting entity undertakes verification of that ACIP information. |
Unusual or potentially suspicious activity |
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How did your staff report unusual or potentially suspicious activity? (Select all that apply)
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Reporting of unusual or suspicious activity Unusual or potentially suspicious activity means any circumstances where you suspect that a person or transaction may be linked to a crime. This includes where you reasonably suspect that a person is committing a crime, is not who they claim to be, or could be a victim of a crime. You or your staff may report unusual or potentially suspicious activity by escalating the matter to a specified person or area within your business or by submitting a suspicious matter report (SMR) directly to AUSTRAC. Internal Reporting processes within your business. External Reports to, and engagement with, AUSTRAC. Online form A digital form that is accessible and editable online. SMR SMR means suspicious matter report. Additional method(s) Select this option if you report methods other than, or in addition to, the methods that are listed. If you enter more than one 'Additional method', please separate them with a comma. |
| Please specify additional reporting methods (internal): (Maximum 200 characters) | |
| Please specify additional reporting methods (external): (Maximum 200 characters) | |
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Please explain why staff did not identify and report any unusual or potentially suspicious activity? (Select all that apply)
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Transaction Monitoring Program (TMP) |
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| Do you have a TMP in place? (Yes or No) | |
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Is your TMP manual, automated or both?
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Transaction Monitoring Program (TMP) Manual Transactions are added to a spreadsheet, or ledger and manually reviewed for any potential anomalies, outliers or unusual activity. Automated A series of predefined rules built into a software program or system. The rules are then run over your transaction data and alerts generate whenever a transaction 'hits' on a rule. |
| Describe the automated systems you use as part of your TMP: (Maximum 500 characters) | |
| Did you review TMP rules in 2023? (Yes or No) |
Transaction Monitoring Program (TMP) rules TMP rules Any rules, logic or thresholds that are used to identify unusual or potentially suspicious transaction activity. |
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What prompted you to review your TMP rules? (Select all that apply)
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Review of TMP rules High ratio of false-positives A significant proportion of the matters identified through a particular rule or threshold are deemed not to be suspicious. Media reports Reports include, but are not limited to, newspaper articles, news websites, social media. Additional reason(s) for review Select this option if you had reason(s) other than, or in addition to, those that are listed. If you enter more than one 'Additional reason', please separate them with a comma. |
| Did your TMP identify any potentially suspicious customer transactions that required further review in 2023? (Yes or No) | |
| Why did your TMP not identify any suspicious customer transactions? (Enter reason below) (Maximum 500 characters) | |
Enhanced Customer Due Diligence (ECDD) |
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| Do you have a documented ECDD program? (Yes or No) | |
| Did you conduct ECDD in 2023? (Yes or No) | |
| Why did you not conduct ECDD in 2023? (Please enter reason for not conducting ECDD in 2023) (Maximum 500 characters) | |
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Which ECDD measures did you undertake in 2023? (Select all that apply)
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Conducting ECDD Extra information gathered Collection of extra information from the customer or third party sources to clarify already collected KYC or beneficial owner information, or to identify the source of wealth and funds of the customer and beneficial owners. KYC information Know-Your-Customer information. Senior management approval An approval by senior management for continuing the business relationship and the provision of a designated service to the customer. Additional method(s) Select this option if you used method(s) other than, or in addition to, those that are listed. If you enter more than one 'Additional method', please separate them with a comma. |
| Do you have a documented procedure in place to record and consider AUSTRAC feedback and guidance? (Yes or No) | |
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What feedback or guidance did you receive? (Select all that apply)
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What did you do in response to this? (Select all that apply)
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Response to AUSTRAC feedback ML/TF ML/TF means money laundering and terrorism financing. Additional action(s) Select this option if you took action other than, or in addition to, those that are listed. If you enter more than one 'Additional action', please separate them with a comma. |
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Thank you for completing the compliance report. AUSTRAC is focussed on providing better assistance and guidance to our reporting entities and your feedback would be appreciated. Please take a moment to answer the following questions. What did AUSTRAC do well to help your compliance? (optional) (Maximum 500 characters) What could AUSTRAC have done much better? (optional) (Maximum 500 characters) |
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